ML17053A456

Final After Action Report, Exercise Date: November 16, 2016, Radiological Emergency Preparedness Program

ML17053A456
Person / Time
Site:	Pilgrim
Issue date:	02/13/2017
From:	Colman S US Dept of Homeland Security, Federal Emergency Management Agency
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML17053A456 (111)

Text

/ U.S. Department of Homeland Security FEMA Regio~ I .

99 High St., S'h Floor Boston, MA 02110-2320 FEMA February 13, 2017 U.S. Nuclear Regulatory Commission Document Control Desk One White Flint North 11555 Rockville Pike, Rockville, MD 20852

Dear Sir/Madam:

Enclosed is the final After Action Report from the November 16, 2016 Pilgrim Nuclear Power Station evaluated exercise. The Commonwealth of Massachusetts and local emergency response organizations successfully demonstrated their capabilities to implement off-site radiological emergency response plans based on a federal team's evaluation of the exercise.

There were no Level 1 or Level 2 Findings as a result of the November 16, 2016 evaluated exercise.

State and local preparedness remains adequate to protect the health and safety of the public living in the.vicinity ~f the Pilgrim Nuclear Power Station and provides reasonable assurance*

that appropriate measures can be taken off-site in the event of a radiological emergency.

. If you have apy questions regarding this matter, please feel free to contact me at (617) 832-4 731 or Taneeka Hollins of my staff, at (617) 956-7523.

]:)fL-£ Steve Colman RAC Chair, Region I Enclosure E-copy: NRC Region I Doug Tift, Regional Liaison, NRC Region I www.fema.gov

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Pilgrim Nuclear Power Station Final After Action Report Exercise Date: November 16, 2016 Radiological Emergency Preparedness Program Published February 13, 2017 FEMA

Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Table of Contents Page I

Table of Contents ...................................................................................................... :... ,...........-....... 3 Executive Summary ........................................................................................................................ 4 Section 1: Exercise Overview......................................................................................... ,......................... 6 1.1 Exercise Details ************************************************************************************"**************************:.6 1.2 Exercise Planning Team Leadership ............................................................................. 6 1.3 Participating Organizations ............................................................................................ 7 Section 2: Exercise Design Summary ........................................................................................... 11 2.1 Exercise Purpose and.Design ........................................................................................... ! i' 2.2 FEMA Exercise Objectives and Core- Capabilities ........................... :........ -.................. 11 2.3 Scenario Summary ............................. :........................................................................ 11 Section 3: Analysis of Capabilities ............................................................................................... 12 3.1 Exercise Evaluation and Results .................................................................................. 12 3.2 Summary Results of Exercise Evaluation .................................................................... 12

• Table 3.2 - Summary of Exercise Evaluation ................................................................. 13 3.3 Jurisdictional Summary Results of Exercise Evaluation .............................................. 18 3.3.1 Commonwealth of Massachusetts ................................................................... 18 3 .3 .2 Risk Jurisdictions ............................................ .

3.3.3 Host Jurisdictions ............................................ .

Section-4: Conclusion ................................................................................................................... 29 Appendix A: Exercise Timeline .................................................................................................... 30 Appendix B: Exercise Evaluators and Team Leaders ..................................................................... 31 Appendix C: Extent of Play Agreement ............................. ~ .........................................................34 Appendix D: Exercise Scenario Summary **************************************************************:********************85 3

Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Executive Summary On November 16, 2016, a Plume Exercise was conducted in the 10-mile plume emergency planning zone (EPZ) around the Pilgrim Nuclear Power Station (PNPS) by the Federal Emergency Management Agency (FEMA), Region I personnel. Out-of-sequence demonstrations of schools and special facilities were also conducted per the new 8-year exercise cycle. The purpose of the exercise and the out-of-sequence demonstrations was to assess the level of State and local preparedness in responding to a radiological emergency. The exercise and out-of-sequence demonstrations were held in accordance with FEMA's policies and guidance concerning the exercise of State and local radiological emergency response plans (RERP) and procedures. The most recent prior full-scale exercise at this site was conducted on April 30, 2014. The qualifying emergency preparedness exercise was conducted on March 3, 1982.

FEMA wishes to acknowledge the efforts of the many individuals in the Commonwealth of Massachusetts; the Massachusetts risk jurisdictions of Carver, Duxbury, Kingston, Marshfield, and Plymouth; the host jurisdictions of Taunton, Bridgewater and Braintree. The.various agencies, organizations, and units of government from these State and local jurisdictions who participated in this exercise are listed in Section III of this report.

Protecting the public health and safety is the full-time job of some of the exercise participants .

and an additional assigned responsibility for others. Still others have willingly sought this responsibility by volunteering to provide vital emergency services to their communities.

Cooperation and teamwork of all the participants were evident during this exercise.

This report contains the final evaluation of the biennial exercise and the evaluation of the following out-of-sequence activities:

Schools and Daycares Duxbury ..

Duxbury High School Duxbury Middle School Chandler Elementary School Alden Elementary School Kinvston, Sacred Heart Early Childhood Center Sacred Heart Elementary School Sacred Heart High School 4

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Unclassified Radiological* Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station P/ymo14.th W ~st Elementary School Plymouth Community Intermediate School

• Plymouth South Middle School Plymouth North High School Plymouth South High, School Special Facilities Duxbury Group Facility and North* Hill Group Facility and Cordwood Plymouth Chilton House Rest Home Host Schools Braintree High School 5

Unclassified

• Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Section 1: Exercise Overview 1.1 Exercise Details Exercise Name _

2016 Pilgrim Nuclear Power Station Radiological Emergency Preparedness (REP)

Program Evaluated Exercise Type of Exercise Plume Full-Scale Functional Exercise Exercise Date(s)

November 16, 2016 Locations See the Extent of Play Agreement in Appendix C for a complete listing of locations.

Sponsors Program Department of Homeland Security (DHS)/Federal Emergency-Management Agency (FEMA) REP Program Mission

Response

Scenario Type Plume Phase Full Participation JIBP Exercise 1.2 FEMA Exercise Planning Team Leadership Steve L. Colman RAC Chair FEMA Region I 99 High St, 5th Floor Boston, MA 02110 617-832-4731 Steve.Colman@fema.dhs.gov John Rice Senior Technological Hazards Specialist FEMA Region I 99 High St, 5th Floor Boston, MA 02110 6

Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station 617-956-7509 John.Rice2@fema.dhs.gov Taneeka Hollins Site Specialist FEMA Region I 99 High St, 5th Floor Boston, MA 02110 617-956-7523 Taneeka.Hollins@fema.~hs.gov 1.3 Participating Organizations .*

Agencies and organizations of the followingjurisdictions participated in the 2016 Pilgrim Nuclear Power Station exercise. .

State Jurisdictions:

Comffionwealth of Massachusetts Massachusetts Department of Mental Health .

Massachusetts Air National Guard Massachusetts pepartment Public Health Massachusetts Department of Corrections Massachusetts Department of Transportation Massachusetts Emergency Management Agency MEMA Region II Massachusetts State Police Massachusetts United Way- 211 Call Center 7

U oclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Risk Jurisdictions:

Town of Braintree Emergency Management Agency Town of Braintree Office of the Mayor Town of Braintree Police Department Town of Braintree School Department Town of Braintree Board of Health Town of Bridgewater School Department Town of Bridgewater Police Department Town of Bridgewater Highway Department Town of Bridgewater Fire Department Town of Bridgewater Emergency Management Agency Town of Bridgewater Building Department Town of Bridgewater Board of Health Town of Carver Transportation Coordinator Town of Carver Special Needs Coordinator Town of Carver Shelter Officer Town of Carver School Liaison

\

Town of Carver Police Department

• Town of Carver Fire Department Town of Carver EOC Staff Town of Carver Emergency Medical Services Town of Carver Emergency Management Agency  !

Town of Carver Council on Aging Town of Carver Board of Selectmen Town of Duxbury Department of Public Works Town of Duxbury Emergency Management Agency Town of Duxbury Fire Department Town of Duxbury Police Department

• Town of Duxbury Regional Communications Center Town of Duxbury School Department Town of Kingston Emergency Management Agency Town of Kingston Fire Department 8

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Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Town of Kingston Police Department Town of Kingston Streets, Trees, and Parks Department Town of Kingston Su.perintendent of Schools Office Town of Marshfield Board of Selectmen Town of Marshfield Dept. of Public Works Town of Marshfield Emergency Management Agency Town of Marshfield Fire Department Town of Marshfield Harbormaster Town of Marshfield Police Department Town of Marshfield School Dept.

Town of Plymouth Community Services Town of Plymouth Council on Aging Plymouth County Sheriff's Dept.

Town of Plymouth Department of Public Work Town of Plymouth ~mergency Medical Service Town of Plymouth Finance Town of Plymouth Fire Department Town of Plymouth Human Resources Town of Plymouth Information Technology Town of Plymouth Inspectional Services Town of Plymouth Marine and Environme~tal Townr of Plymouth OEM-CERT Town of Plymouth Office of Emergency Management Town of Plymouth Planning and Development , .

Town of Plymouth Police Town of Plymouth Public Health Town of Plymouth Schools Town of Plymouth Town Management 9

Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Power Nuclear Power Station Support.Jurisdictions:

Town of Braintree Emergency Managem~nt Agency Town of Braintree Office of the Mayor Town of Braintree Police Department' Town of Braintree School Department Town of Braintree Board of Health Town of Bridgewater School Dept.

Town of Bridgewater Police Dept.

Town of Bridgewater Highway Dept.

Town of Bridgewater Fire Department Town of Bridgewater Emergency Management Agency Town of Bridgewater Building Department Town of Bridgewater Board of Health City of Taunton Community Volunteers City of Taunton Emergency Management Agency City of Taunton Engineer* Department City of Taunton Mayor's Office City of Taunton Police Department City of Taunton Public Works Department City of Taunton School Department City of Taunton Veterans Department City of Taunton Water Department Private Organizations:

Entergy Nuclear American Red Cross Federal Agencies:

Federal Emergency Management Agency Nuclear Regulatory Commission United States Coast Guard 10

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Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Section 2: Exercise Design Summary 2.1 Exercise Purpose and Design The purpose of this report is to present the results and findings on'the performance of the offsite response organizations (OROs) during a simulated radiological emergency.

FEMA Region I evaluated a biennial exercise (Plume Phase) for Pilgrim Nuclear Power Station on November 16, 2016. The exercise was designed to assess the capabilities of state' and local emergency preparedness organizations in implementing their Radiological Emergency Response

• Plans (RERPs) and procedures to protect the public health and safety during a radiological emergency involving Pilgrim Nuclear Power Station.

2.2 FEMA Exercise Objectives and Core Capabilities The exercise objec~ives, capabilities, and activities are noted in the extent of play agreement, included in Appendix C, Exercise Plan.

2.3

• Scenario Summary The exercise scenario was developed to evaluate the exercise participants' response to a radiological emergency.

11

Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Section 3: Analysis of Capabilities 3.1 Exercise Evaluation and Results This section contains the results and findings of the evaluation of all jurisdictions and functional entities that participated in the November 16, 2016 plume exercise and out-of-sequence (OOS) interviews and demonstrations during the 2016 exercise cycle.

Each jurisdiction and functional entity was evaluated based on their demonstration of Capabilities and their equivalent REP criteria as delineated in the FEMA REP Program Manual dated January 2016. Detailed information on the evaluation criteria and the extent of play agreement for this exercise are included as appendices in this report.

3.2 Summary Results of Exercise Evaluation The matrix presented in the table on the following pages presents the status of all exercise evaluation area criteria that were scheduled for demonstration during the exercise.

Exercise criteria are listed by number, and the demonstration status of those criteria are indicated by the use of the following letters:

• M : Met (no level 1 or level 2 findings assessed and no unresolved findings from prior exercises)

• Fl: Level 1 finding (formerly LEVEL 2 FINDINGS ) assessed

• F2: Level 2 finding (formerly area requiring corrective action) assessed or unresolved from a prior exercise

• P: Plan issue

• N : Not demonstrated Note: Blank fields indicate criterion was not evaluated at that location.

12

Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Table 3.2 - Summary of Exercise Evaluation u

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Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Support Operations/Facilities Monitoring, Decontamination, and Registration ofEvacuees 6al Monitoring and Decontamination..ofEmergency Workers and their Equipment 6bl and Vehicles 14

Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Power Nuclear Power Station Table 3 .1 - Summary of Exercise Evaluation (Continued. page 2/3)

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Unclassified Radio logical Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Table 3.1 - Summary of Exercise Evaluation (Continued. page 3/3)

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Implementation of Protective Actions for persons with disabilities and 3c2 M M M M M M N N N N access/functional needs( schools)

Implementation of Traffic and Access Control 3dl Implementation ofTraffic and Access Control 3d2 Implementation oflngestion Pathway Decisions 3el Implementation oflngestion Pathway Decisions 3e2 Implementation of Post-Plume Phase Relocation, Reentry, and Return 3fl Decisions Field Measurement and Analysis RESERVED 4al Plume Phase Field Measurement and Analyses 4a2 P lume Phase Field Measurement and Analyses 4a3 Post Plume Phase Field Measurements and Sampling 4bl Laboratory Operations 4c l Emergency Notification and Public fnfo Activation of the Prompt Alert and Notification System 5al RESERVED 5a2 Activation of the Prompt Alert and Notification System 5a3 Activation of the Prompt Alert and Notification System 5a4 Emergency Information and Instructions for the Public and the Media 5bl 16

Unclassified Radiological Emergency Preparedness Program After Action Report 2016 Pilgrim Nuclear Power Station Support Operations/Facilities Monitorin11:. Decontamination, and Re11:istration ofEvacuees 6al Monitoring and Decontamination ofErnergency Workers and their Equipment 6bl and Vehicles Temporary Care of Evacuees 6cl Transportation and Treatment of Contaminated Injured Individuals 6dl 17

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3 Criteria Evaluation Summaries 3.3.1 Commonwealth of Massachusetts 3.3.1.1 MA State Emergency Operations Center In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET:* l.a.l, l.c.l, l.d.l, l.e.l, 2.a.l, 2.b.l, 2.b.2, 2.c.l, 3.b.l, 3.c.l, 3.d.l, 3.d.2, 5.a.l, 5.b.l

b. LEVEL 1 FINDING: None

c. LEVEL 2 FINDING: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.2 MA 211 Call Center In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: l.d.l, l.e.l, 5.b.l.

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.1.3 MA Region II EOC In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: l.a.l,'l.b.l, l.c.l, l.d.l, l.e.l, 3.a.l, 3.b.l, 3.c.l, 3.c.2.,

3.d.1, 3.d.2, 5.bl

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None 18

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.1.1.4 MA (PNPS) Emergency Operations Facility In summary, the status ofDHSlFEMA criteria for this location is as follows:

a. MET: I.a.I, 1.c.1, 1.d.1, 1.e.1, 2.a:l, 2.b.l, 2.b.2, 2.c.1, 4.a.2.

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f.

• PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.1.1.5 MA (PNPS) Field Monitoring Team-1 In. summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: 1.d.1 (All other criteria Observed only demonstrated during 2016 Seabrook Exercise)

b. LEVEL 1 FINDINGS  : None .

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: 1.d.l (2016 Seabrook)

g. PRIOR ISSUES - UNRESOLVED: None 3.1.1.6 MA (PNPS) Field Monitoring Team-2 In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: Observed only (demonstrated during 2016 Seabrook Exercise)

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 19

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan. Pilgrim Nuclear Power Station 3.1.1.7 MA (fNPS) Joint Information Center In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: 1.a.1,1.c.l, l.d.1,.1.e.l, 3.b.l,. 5.b.l.

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None .

f. PRIOR -ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2 Risk Jurisdictions 3.3.2.1 Carver Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: l.a.l, l.c.l, l.d.l, Le.I, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 5.b.l.

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.2 Duxbury Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: I.a.I, l.c.l, l.d.l, Le.I, 3.a.l, 3.b.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 5.b.l.

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 20 -~

Unclassified Radiological Emergency Preparedness Progiam (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.2.3 Duxbury High School In summary, the status ofDHS/FEMA criteria for this location is as follows:

a~ MET: l.a.1, 3.b.1, 3.c.2

b. LEVEL I FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES :. UNRESOLVED: None 3.3.2.4 Duxbury Middle School In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: I.a.I, 3.b.1, 3.c.2 *

b. LEVEL I FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: Norte 3.3.2.5 Chandler Elementary School

. In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: l.a.1, 3.b.1, Jc.2 -

b. LEVEL I FINDINGS  : None

c. LEVEL 2 FINDINGS.  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.6 Alden Elementary School .

In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: I.a.I, 3.b.1, 3.c.2

b. LEVEL I FINDINGS  : None 2I.

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f.

• PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.6.1 North Hill Group Facility (Duxbury)

• In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET:None

b. LEVEL I FINDINGS: None

c. LEVEL2FINDINGS:None

d. PLAN ISSUES: None

• e. NOT DEMONSTRATED: I.a.I, 3.b.l, 3.c.2 (will be demonstrated in20I 7)

f. PRIOR ISSUES- RESOLVED: None ,

g. PRIOR ISSUES- UNRESOLVED: None 3.3.2.6.2 Cordwood Group Facilities (Duxbury)

In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET:None

b. LEVEL I FINDINGS: None

c. LEVEL2FINDINGS:None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: I .a. I, 3 .b.1, 3 .c.2 (will be demonstrated in 20 I 7)

f. PRIOR ISSUES- RESOLVED: None

g. PRIOR ISSUES- UNRESOLVED: None 3.3.2. 7 Kingston MA Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: I.a.I, l.c.l, l.d.l, Le.I, 3.a.I, 3.c.1, 3.c.2, 3.d.l, 3.d.2, 5.b.l.

b. LEVEL I FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 22

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.2.8 Sacred Heart Early Childhood Center In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: 1.a.1, 3.b.l, 3.c.2

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None

• 3.3.2.9 Sacred Heart Elementary School In summary, the status of DHS/FEMA criteria for this location is as follows: . **

a. MET: 1.a.l, 3.b.l, J.c.2

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.10 Sacred Heart High School In summary, the status of ~HS/FEMA criteria for this location is as follows:

a. MET: 1.a.l, 3.b.l, 3.c.2

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES- UNRESOLVED: None 23

• Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.2.11 Marshfield Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: l.a.1, l.c.l, l.d.l, l.e.l, 3.a.l, 3.c.l, 3.c.2, 3.d.l, 3.d.2, 5.b.l.

b. LEVEL 1 FINDINGS : None

c. LEVEL 2 FINDINGS : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.12 Plymouth Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows:

• a. MET: I.a.I, l.c.l, l.d.l, l.e.l, 3.a.l, 3.c.l, 3.c.2,'3.d.l, 3.d.2, 5.b.l.

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 24

Uoclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.2.13 West Elementary School In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: I.a.I, 3.b.l, 3.c.2

h. LEVEL I FINDINGS  : None

1. LEVEL 2 FINDINGS  : None J. PLAN ISSUES: None

k. NOT DEMONSTRATED: None I. PRIOR ISSUES - RESOLVED: None

m. PRIOR ISSUES - UNRESOLVED: None 3.3.2.14 Plymouth Community Intermediate School In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: I.a.I, 3.b.l, 3.c.2.

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.15 Plymouth South Middle School In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: I.a.I, 3.b.l, 3.c.2.

b. LEVEL 1 FINDINGS :None

c.

• LEVEL 2 FINDINGS :None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 25

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.2.16 Plymouth North High School In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: I.a.I, 3~b.l, 3.c.2.

b. LEVEL 1 FINDINGS :None

c. LEVEL 2 FINDINGS :None

d. *PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.17 Plymouth South High School In summary, the status ofDHS/FEMA criteria for this -location is as follows:

a. MET: I.a.I, 3.b.l, 3.c.2.

b. LEVEL 1 FINDINGS :None

c. LEVEL 2 FINDINGS :None

d. PLAN ISSUES:. None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.2.18 Chilton House Rest Home In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET:None

b. LEVEL 1 FINDINGS: None

c. LEVEL2 FINDINGS: None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: I.a.I, 3.b.l, 3.c.2 (will demonstrated in2017)

f. PRIOR ISSUES- RESOLVED: None

g. PRIOR ISSUES- UNRESOLVED: None 26

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.3 Support Jurisdictions 3.3.3.1 Braintree Local EOC In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: l.a.l, l.c.l, l.d.l, l.e.l, 3.d.1, 3.d.2, 5.b.1 *

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: Non 3.3.3.1.2 Braintree High School In summary, the status ofDHS/FEMA criteria for this location is as follows:

a. MET: Non.e (Not Evaluated)

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: l.a.l, 3.a.l, 3.c.2 (moved to next year)

f. PRJOR ISSUES- RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 3.3.3.2 Bridgewater Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: l.a.l, l.b.l, l.c.l, 1.d.l, Le.I, 3.d.l, 3.d.2,

b. LEVEL 1 FINDINGS  : None

c. LEVEL 2 FINDINGS  : None

d. PLAN ISSUES: None

e. NOT DEMONSTRATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 27

U oclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station 3.3.3.3 Taunton Local EOC In summary, the status of DHS/FEMA criteria for this location is as follows:

a. MET: La.I, Lb.l, Le.I, Ld.l, Le.I, 3.a.l, 3.c.1, 3.d.1, 3.d.2,

b. LEVEL 1 FINDINGS : None

c. LEVEL 2 FINDINGS : None

q. PLAN ISSUES: None

e. NOT DEMONS1RATED: None

f. PRIOR ISSUES - RESOLVED: None

g. PRIOR ISSUES - UNRESOLVED: None 28

• • --------- -----*--- *r -*

-~--

-*-- - - -* ' --.__ :_- -* _.: _ ::_...:.:__-_-_:*_ - _:__ _:__-:--:,,* __:__ *. .::. -* -- -=-- -~-=----* --- .:. . . . ...:. .. _-- -- -- - -- ---- - - -- -------- ----- -__::-_**- - .. -~-- -_ -- ---_-:- : :_ ---- -

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan _Pilgrim Nuclear Power Station Section 4: Conclusion The state and local organizations, except where noted in this report, demonstrated knowledge of their emergency response plans and procedures. All activities were implemented as they would be in an actual emergency unless specified otherwise in the extent of play agreement.

There were no "Findings" identified during this exercise. One prior "Finding" from the 2016 Seabrook Station Plume Exercise was resolved.

29

Unclassifi ed Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Appendix A: Exercise T imeline EXERCISE TIMELINE Date and Site: November 14- 18, 2016; PilgrimNuclear Powet Plant

~o

~usual Event T t*l.Ml

• EJlllt 08 14 1EOC 0825 IA 2:11 llEll 112 0!!24 liWT It liWT a

r-TWloliil I UC NA Ell' 0824 lian~ . . . arAdima~T-.

ea,,.,

EOC 0824 r.,_

EOC 0824 Dudllly EllC 0824 l;nliiell EOC 0824 EOC 0824 T-EOC 0824 sm,.-

EOC 0824 in..r...

EllC 0825 Alert 0851 D901 0005 0008 0852 0900 0904 0002 QQll2 OIKl1 0001 OIKl2 0008 Si.e hea Emergerey 1027 1033 1005 1028 1D27 1036 1037 1042 1034 1033 1046 1033 1037 General Emergency 11 31 1138 1143 1133 1131 1'140 1142 1138 1145 1138 11311 1139 1141 Sinwted RadioadM!y 1043 1046 1050 1104 1()43 1D55 1052 1138 1027 1D55 1.05e 1051 1D5!i Release Began Sinwted RadioadM!y 1231 NA NA 1303 tZ31 NA 1304 NA NA NA NA NA NA Release Terminaied Faciity Declared Opera1ionai 0915 Oll08 HXl3 0948 0900 0835 0912 0927 0900 OQ32 0900 08!i7 Gov Dec!aratioo c:i state c:i Emergency 1000 1008 1000 1006 1006 1012 1000 1025 1010 1000 1016 1026 Oedaraiion a Local Emergency NA NA NA 0913 1000 0945 0055 ooro 1014 112D 0008 Exen:ise Tennina.ied 1303 1303 1303 1306 1305 1304 1307 1305 1303 13D!i 1303 1.:113 Pn!cautiooary Actions:

Si1!n Soimed Area 4 (Plymoo1h NA NA NA NA NA NA NA NA NA Dll44 NA NA NA EOC)

Close Parks DQ54 09!i7 1008 1000 0925 1004 1026 1107 Dll5ll 11D7 NA 1010 Reslrid W* Traffic [)Q3!i 0944 1000 1000 0925 1004 1D26 1107 00311 Ol!48 0052 1010 Rl!5iricl Rail Traffic 1048 NA 1240 1000 0925 1004 1026 1107 @39 Ol!48 0052 1010 Re5lrid Air5Dace 1048 NA 12411 1000 0925 1.004 1026 1107 0039 004S Dll52 1010 Shelll!r IM!slcc:t. s1Dr1!d feed, & water 1027 1057 1008 1026 1113 1114 1026 1107 1108 1107 1111 1010 Sc:hoot Transfers 11944 NA OQ50 NA 09!i!i (Jg5ij NA NA NA 004S 09!i2 OQ44 1<< A&N OecisK>n '1055 1057 1100 NA 1113 1028 1114 1100 11 00 '11115 NA NA 1* Sil!n Activation 11D7 1107 1107 NA 1107 1107 1107 1107 11117 1107 1106 1107 1<< EAS Messaoe 1110 1110 1110 NA 1'1 1D mo ma 1110 1110 t11 0 11'1D 1110 pJ MN Decision 1153 1153 1156 NA 1205 1204 12!17 1200 11 56 1157 1156 NA pJ Siren Activaliln 12!15 1205 1205 NA 1205 '12D!i 1205 1205 1205 12!15 1205 NA pJ EAS Messaae 1208 1208 1208 NA 1208 1208 1208 1208 1208 1208 1208 1238 Kl Decision:

EWs advised tD take Kl 1055 1D!i7 1104 1055 1113 H2tl 11 14 1110 1110 11D7 1100 NA General Public advised to lake Kl 1055 1D!i7 1104 1055 11 13 1114 1114 1110 1110 '1107 1106 1113

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Appendix B: Exercise Evaluators and Team Leaders 2016 Pilgrim Station Plume Evaluator Assignments Steve Colman- RAC Chair John Rice- Senior Site Specialist Taneeka Hollins- Pilgrim Site Specialist Location Evaluator Criteria MA SEOC Ingrid Pierce (TL) lcl, Sal Barbara Thomas lal, ldl , lel, 5.b.1 Helen Laforge 3bl , 3cl, 3dl, 3d2 Mike Howe 2al, 2bl, 2b2, 2cl MA211 Larry Broockerd ldl, lel , 5bl MEMAR2 Bill Webb (TL) lcl Nick Buls lal , ldl , lel , 5bl Bill McDougall 3al,3bl,3cl,3c2,3dl,3d2 nc Linda Gee (TL) lal, lcl, ldl , lel, 5bl EOF Ken Wierman (TL) lal, lcl , ldl, lel , 4a2 Tim Pflieger 2al, 2bl, 2b2, 2cl FMTl Nan Calhoun OBSERVED ONLY FMT2 Korky Dulgerian OBSERVED ONLY CarverEOC Mike Shuler (TL) lal , lcl, ldl , lel , 5bl Patti Gardner 3al, 3cl , 3c2, 3dl, 3d2 *(impediment inject)

Kingston EOC Lee Torres (TL) lal, lcl, ldl , lel, 5bl Tina Lai-Thomas 3al,3cl,3c2,3dl ,3d2 DuxburyEOC Brian Hasemann (TL) lal , lcl , ldl , lel , 5bl Miriam Weston 3al ,3cl,3c2,3dl,3d2 Marshfield EOC Lauren DeMarco (TL) lal , lcl, ldl , lel , 5bl Pat Foster/ TJ Swenson (OJT) 3al,3cl, 3c2, 3dl, 3d2 31

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station Plymouth EOC Joe Suders (TL) lal , lcl , ldl , lel , 5bl Lisa Rink 3al , 3cl , 3c2, 3dl , 3d2 Taunton EOC Ryan Jones (TL) lal , lcl , ldl , lel Rufus Mobley 3al , 3dl , 3d2, 5bl Bridgewater EOC Mark Dalton- ICF (TL) lal , lcl , ldl , lel Kent Tosch - ICF 3al , 3dl , 3d2, 5bl Braintree EOC Tom Hegele - ICF (TL) lal , lcl , ldl , lel Bruce Swiren - ICF 3al , 3dl , 3d2, 5bl

• Schools/Special Facilities- Evaluated Out of Sequence by Taneeka Hollins (Site Specialist 32

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/Improvement Plan Pilgrim Nuclear Power Station This page is intentionally blank 33

Appendix C: Extent of Play A1:reement PU,GBIM NIJCLEAB POWER STATION EXEBCJSE - Noyember 16 2016 MASSACHUSETTS EVALUATIONAREASANDEXTENTOFPLAY Overview The following organizations/locations will demonstrate in 2016:

State Emergencv Operations Center Massachusetts Emergency Management Agency Massachusetts Department of Pub lic Health Massachusetts State Police MassDOT Massachusetts National Guard Massachusetts Department of Mental Health Office of the Secretary of the Commonwealth US Coast Guard American Red Cross Federal Emergency Management Agency Region l Pilgrim Nuclear Power Station Liaison MASS 211 Call Center Region D Emergency Operations Center Massachusetts Emergency ManagementAgency-Region II Massachusetts State Police Mass DOT Massachusetts National Guard Pilgrim Nuclear Power Station Liaison American Red Cross MBTARepresentative Department ofCorrections- Bridgewater Plymouth County SheriffEmergency Management Agency Emergency Operations Facility Massachusetts Emergency Management Agency Massachusetts Department ofPublic Health/Radiation Control Program Pilgrim Nuclear Power Station Radiological Field Monitoring and Sampling Teams Massachusetts DepartmentofPublic Health/Radiation Control Program Pilgrim Nuclear Power Station Joint Information Center Massachusetts Emergency Management Agency Pilgrim Nuclear Power Station EAS Radio Station WBZ 1030AM RiskJurisdictions CarverEOC DuxburyEOC Kingston EOC Marshfield EOC PlymouthEOC Pilgrim EOP Rev. 0 rage 1 01 so 01121116

PU,GBJM NI JQ.EAR POWER STATION EXERCJSE- November 16 2016 Sup portJu risdi ctions Braintree Command Center Bridgewater EOC TauntonEOC The following demonstrations were conducted out of sequence Summer 20 l6 Mass State Police Dosimetry Demonstration MS I Hospital- Good Samaritan Hospital September 29, 2016 SchoolsandDaycares:

Duxbury:

Duxbury High School Duxbury Middle School Chandler Elementary School Alden Elementary School Kingston:

Sacred Heart Early Childhood Center Sacred Heart Elementary School Sacred Heart High School Plymouth:

West Elementary School Plymouth Community Intermediate School Plymouth South Middle School Plymouth North High School Plymouth South High School Special Facilities Duxbury:

• Group Facility and North Hill Group Facility and Cordwood Plymouth:

Chilton House Rest Home HostSchools:

Braintree High School Per FEMA Region I Memorandum dated, February 27, 2012, "On the Spot" corrections as outlined in Rgcqmmgndqtiqn Tnjtiqtiyg 1 5 - Correct Issues fmny:diqtetv is approved for the following criterion: l.d.l, Le.I, 3.a.l, 3.b.l, 3.d.l, 3.d.2, 4.a.3, 4.b.J, 5.b.J, 6.a.1, and 6.b.J.

Pilgrim EOP Rev. 0 Page 2 of 50 07/27/16

PU ,GBIM MfCJ,EAB POWER STATION EXERCISE- Noyember 16, 2016 EVALUAUONAR£A T* Emergency Qnemtiqny Mqnqgemen(

ISub-element J.a-Mobilization Intent This sub-element is derivedfrom ll/UREG-0654/FEMA -REP-J, which requires that Oifsite Response Organizations (ORO) have the capability to alert, notify, and mobilize emergency personnel and activate and staffemergencyfacilities.

Criterion 1. a. I : 0 ROs use effective procedures to alert, notify, and mobilize emergency personnel and activate facilities in a timely manner. (NUREG-0654/FEMA-REP-J, A.ia, e;

~~~CL~~D~EL~G~~U~~

Extent ofPlay Responsible OROs must demonstrate the capability to receive notification ofan incident.from the licensee, verify the notification, and contact, alert, and mobilize key emergency personnel in a timely manner and demonstrate the ability to maintain and staif24-hour operations. Twenty-four hour operations can be demonstrated during the exercise via rosters or shift changes or otherwise in an actual activation. Local responders must demonstrate the ability to receive and/or initiate notification to the licensees or other respective emergency management organizations ofan incident in a timely manner, when they receive information from the licensee or alternate sources. Responsible OROs must demonstrate the activation offacilities fo r immediate use by mobili:::ed personnel upon their arrival.

Activation offacilities and staff, including those associated with the ICS, must be completed in accordance with ORO plans/procedures. The location and contact information for facilities included in the incident command must be available to all appropriate responding agencies and the NP P after these facilities have been activated.

Pre-positioning ofemergency personnel is appropriate, in accordance with the Extent-of-Play Agreement, at those facilities located beyond a normal commuting distance from the individual 's duty location or residence. This includes the staggered release ofresources.from an assembly area.

Additionally, pre-positioning ofstajffor out-of-sequence demonstrations may be used in accordance with the Extent-of-Play Agreement.

The REP program does not evaluate Incident Command Post tactical opera1ions (e.g. , Law Enforcement hostile action suppression techniques), only coordination among the incident command, the utility, and all appropriate OROs, pursuant to plans/procedures.

Initial law enforcement,fire service, HA Z:MAT, and emergency medical response to the NP P site may impact the ability to staff REP functions. The ability to identify and request additional resources or identify compensato1y measures must be demonstrated. Exercises must also address the role ofmutual aid in the incident, as appropriate. An integral part ofthe response to an HAB scenario at an NPP may also be within the auspices ofthe Federal Government (e.g. , FBI, NRC, or DHS). Protocols for requesting Federal, State, local, and Tribal law enforcement support must be demonstrated. as appropriate. Any resources must be on the ORO 's mobilization list so they can be contacted during an incident, ifneeded.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of-Play Agreement.

Pilgrim EOP Rev. 0 Pagel of SO 07/27/16

W .GBIM NI!Q;EAB POWER STATION J;XEBCJSE- Nsiygmbcr 16 2016 Massachusetts Extent ofPlay State EOC-Massachusetts Emergency Management (MEMA) SEOC emergency staff, including the I Commented [CK(1]:

Massachusetts Emergency ManagementTeamstaff(Massachusetts DepartmentofPublicHealth (MDPH), Massachusetts Department ofT ransportation (MassDOT), Massachusetts Department ofMental Health (MDMH), Massachusetts State Police (MSP), US Coast Guard, ;Massachusetts IArmy National Guard (MANG), and American Red Cross (ARC), the State Public Information Line (Mass 211) staff, the Federal Emergency Management Agency (FEMA), *a nd the Pilgrim Nuclear Power Station Liaison will be pre-staged at TBD in the SEOC cafeteria, and upon notification, will report to the EOC, using a ten-minute per hour travel time . The notification process will be completed, and call down rosters will be shown to the FEMA Evaluator.

The MASS 211 Call Center will be activated for an event at Pilgrim Station.

Region II EOC- MEMA Region II EOC staff and emergency volunteer staff will pre-staged at TBD outside the Region II EOC, and upon notification, will report to the Region Il EOC, using a ten-minute per hour travel time (note: MEMA Region II staff who report prior to TBD will report at their normal reporting time) . The notification process will be completed and call down rosters will be shown to the FEMAEvaluator.

the EOF, and upon notification, will report to the EOF using the I 0 minute to hour travel time .

Joint Information Center (JlC}--MEMA personnel will be pre-staged in tbe area of the JlC and upon notification, will report to the JlC using the 10 minute to hour travel time NIA T Field Monitoring Team Personnel-Field Team personnel wi ll be pre-staged at the EOF and upon notification, will report to the EOF using the I 0 minute to hour travel time.

Local EOCs--Local EOC emergency response staff will be pre-staged at TBD outside the local EOC and upon notification, will report to the EOC, using a ten-minute per hour travel time .

State Police Troop D- Will dispatch representatives to the Region II EOC, but traffic and access control personnel will not be mobilized (see Evaluation Area 3.d.).

Plymouth Countv Sheriff's Emergency Management Agency CPCSEMA)-Will demonstrate communications with emergency staff and obtain ETA; however, staff and vehicles wiU not be mobilized, except for the PCS EMA liaison who wiU report to the MEMA Region U EOC.

Transportation Providers -Calls will be made to all transportation providers to verify the contact information. FEMA will evaluate the contact of the transportation providers during the practice exercise.

A Controller message will refer to the matrix to provide the number of vehicles and drivers available for exercise play. No vehicles or personnel will be mobilized .

Level l or Level 2 Findings: NIA Pil&rim EOP Rev. 0 Page 4 of 50 07127116

PU ,GBIM NI JCl,f;AB POWER STATION EXf:BQSE - Ngyemhcr 16 2016 ISub-element I. b- Facilities Intent This sub-element is de rived from NUREG-0654/FEMA -REP-I, which requires thatO.ffsite Response Organizations (ORO) have facilities to support the emergency response.

Criterion 1. b.1: Facilities are sufficient to support the emergency response.

(NUREG0654/FEMA-REP-1, G.3.a; H.3; J.10.h; J.12; K.5.b)

Extent of Play Responsible OROs must demonstrate, no less than once evety 8 years, the ava ilability offacilities to support accomplishment of emergency operations. This includes all alternate and backup f acilities.

Evaluations are typically performed/or EOCs andJ!Cs, as well as other f acilities such as reception/relocation centers. Some ofthe areas evaluated within the f acilities are adequate space, furnishings, lighting, restrooms, ventilation, access to backup power, and/or alternate f acility, ifrequired to support operations. Radio stations, laboratories, initial warning points and hospitals are not evaluated under l .b.I .

In addition.facilities will be evaluated/or this criterion during the first biennial exercise after any new or substantial changes in structure, equipment, or mission that affe ct key capabilities, as 0111lined in respective emergency plans/procedures. .4 substantial change is one thar has a direct effect or impact on emergency response operations performed in those facilities. Examples of substantial changes include modifying the si=e or configuration ofan emergency operations center, adding more functio n to a center, or changing the equipment available/or use in a center.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or othen vise specified in the Extent-of-Play Agreement.

Massachusetts Extent of Play There are no new or renovated facilities within the Pilgrim Massachusetts EPZ. The Bridgewater Reception Center facility at the Tinsley Center were evaluated in 2015.

There will not be a FEMA evaluation of alternate or backup facilities during this exercise Level 1 or Level 2 Findings: N/A Pil&rim EOP Rev. 0 Page 5 of50 07n7/16

PU .GRCM NJ ICI.EAR POWER STATJON EXERCISE- Noycmber 16, 2016 ISub-element 1.c - Direction and Control Intent This sub-element is derived.from NUREG-0654/FEMA-REP-l , which requires thatOifsite Response Organizations (ORO) have the capability to control their overall response to an emergency.

Criterion 1.c.J: Key personnel with leadership roles for the ORO provide direction and control to that part ofthe overall response effort for which they are responsible. (NUREG-0654/FEMA-REP-1, A.1.d; A.2.a, b; A.3; C4, 6)

Extent of Play Leadership personnel must demonstrate the ability to carry out the essential managementfimctions ofthe response effort (e.g., keeping staffinformed through periodic briefings and/or other means, coordina1ing with other OROs, and ensuring completion ofrequirements and requests.) Leadership must demonstrate the ability to prioritize resource tasking and replace/supplement resources (e.g. , through MO Us or other agreements) when faced with competing demands for finite resources. Any resources identified through LOA/ MO Us must be on the ORO 's mobili=ation list so they may be contacted during an incident, if needed.

All activities must be pe1formed based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless 01herwise noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent ofPlay If a local EPZ community is directed to evacuate, key EOC personnel will simulate closing and relocation of the EOC through a discussion oflogistics with the FEMA Evaluator. Closing of the local EOC and relocation will be simulated.

Level 1 or Level 2 Findings: NIA Pilcrim EOP Rev. 0 Pace 6 of SO 07/27/16

PI T.GBCM NI JCJ, t; AB POW ER ST ATIO N EXEB CISE-Noyemher 16 2016 IS ub-element l. d- Communications Equipment I ntent This sub-element is derivedfrom NUREG-0654/FEMA-REP-l. which requires that Offsite Response Organizations (ORO) establish and operate reliable primary and backup communication systems to ensure communications with key emergency personnel at locations such as contiguous governments within the emergency planning =one (EPZ) : Federal emergency response organizations, the licensee and itsfacilities, emergency operations centers (EOC), Incident Command Posts andfield monitoring teams.

Criterion 1.d.l: At least two communication systems are available, at least one operates prop erly, and communication links are establish ed and maintainedwith appropriate locations.

Communications capabilities are managed in support ofemergency operations. (NUREG-0654/FEMA-REP-l, F.J, 2)

Extent ofPlay OROs must demonstrate that a primary system and at least one backup system arefully fimctional at all times. Communications systems are maintained and tested on a recurring basis throughout the assessment period and system status is available to all operators. Periodic test results and corrective actions are maintained on a real time basis. Ifa communications system or systems are notfunctional, but exercise performance is not affected, no exercise issue will be assessed Communications equipment and proceduresfor facilities andfield units are used as neededfor transmission and receipt ofexercise messages. Al/facilities, FMTs and incident command must have the capability to access at least one communication system that is independent ofthe commercial telephone system.

Responsible OROs must demonstrate the capability to manage the communication systems and ensure that all message traffic is handled without delays that might disrupt emergency operations. OROs must ensure that a coordinated communication link for fixed and mobile medical support facilities exists. Exercise scenarios may require the failure ofa communications system and use ofan alternate system, as negotiated in the extent ofplay agreement.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless othenvise noted above or othenvise specified in the extent ofplay agreement.

Massachusetts Extent of Play Contact with locations not playing will be simulated.

Level l or Level 2 Fi ndings: N/A Plan ning Issues:

Condition:

NIAT Field Teams during the April 5, 2016 Graded Seabrook Exercise did not demonstrate to two different communications systems.

Possib le Cause:

NIAT Field Teams used cell phones and laptops with air card that relied on cell service and therefore were not considered two different forms of communications.

Effect:

All communication means are vulnerable to failure or inoperability of a single, local cellular tower network.

p;1goim ESP Ru. 9 Pa,c 7 of59 97i'i7fl6

PU ,GB IMNIJQ ,f;AB POWER ST ATION EXEBCJSE- Nqyemher 16, 2016 Recommendation:

NIAT Field Teams will be equipped with portable radios as the alternate means of communications.

FEMA will evaluate this planning issue during the practice exercise. This activity will be evaluated by FEMA at the EOF prior to the Field Teams leaving for the fie ld.

Note: If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an "on the spot" training by the local or State representative, the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day.

Pilcrim EOP Rev. 0 Page8 of SO 07n7/16

PU ,QBIM Nl lCJ,EAB POWER STATION EXEBCJSE - N9yember 16. 2016 Sub-element 1. e - Equipment and Supplies to Support Operations Intent This sub-element is de rivedfrom NUREG-0654/FEMA-REP-l , which requires thatO.ffsite Response Organizations (ORO) have emergency equipment and supplies adequate to support 1he emergency response.

Criterion I.e./: Equipment, maps, displays, monitoring instruments dosimetry, potassium iodide (KI), and other supplies are sufficient to support emergency operations. (NUREG-0654/FEMA-REP-l, H. 7, JO; L 7, 8, 9; J.10.a, b, e; J.11, 12; K3.a; K5. b)

Extent ofPlay A particular fac ility 's equipment and supplies must be sufficient and consistent with thatfacility 's assigned role in the ORO 's emergency operations plans. Use ofmaps and other displays is encouraged.

For non-facility-based operations, the equipment and supplies must be sufficient and consistent with the assigned operational role. At locations where traffic and access control personnel are deployed, appropriated equipment (e.g., vehicles, barriers, traffic cones and signs) must be available, or their availability described.

Specific equipment and supplies that must be demonstrated under this criterion include KI inventories, dosimetry, and monitoring equipment, as follows:

KI: Responsible OROs must demonstrate the capability to maintain inventories ofKI sufficiemfor use by:

( /) emergency workers; (2) institutiona/i=ed individuals, as indicated in capacity listsforfaci/ities; and (3) where stipulated by 1he plans/procedures, members ofthe general public (including transiems) within 1he plume pathway EPZ. In addition, OROs must demonstrate provisions to make KI available to specialized response teams (e.g., civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMAT, or other ancillary groups) as identified in plans/procedures. The plans/p rocedures must include the forms to be usedfor documeming emergency worker ingeslion ofKI, as well as a mechanism fo r identifaing emergency workers that have declined KI in advance. Consider carefully the placement ofemergency workers 1ha1have declined KI in advance.

ORO quantilies ofdosimet1y and KI available and storage localions(s) will be corifirmed by physical inspeclion al the storage location(s) or through documentalion ofcurrent inven101y submilled during the exercise, provided in the ALC submission, and/or verified during an SA V Available supplies ofKI must be within the expiration date indica1ed on KI bottles or blister packs. As an alternative, the ORO may produce a /etterfrom a certified private or Slate laboratory indicating that the KI supply remains potent, in accordance with US. Pharmacopoeia slandards.*,

Dosimetry: Sufficient quanlities ofappropriate direct-reading and permanent record dosimetry and dosimeter chargers must be available for issuance 10 all emergency workers who will be dispatched to pe1form an ORO mission. Jn addition, OROs must demonstrate pr!lVisions to make dosimetry available 10 speciali=ed response teams (e.g. , civil support team, Special Weapons and Tactics Teams, urban search and rescue, bomb squads, HAZMA T, or other ancillary groups) as identified in plans/ procedures.

Appropriate direct-reading dosimetry must allow an individua/(s) lo read the administrative reporting limits and maximum exposure limits contained in the ORO 's plans/ procedures.

Direct-reading dosimeters must be =eroed or operationally checked prior lo issuance. The dosimelers must be inspectedfor electrical leakage at leas/ annually and replaced when necessmy. Civil Defense Victoreen Model J38s (CD V-138s) (0-200 mR), due to /heir documented history ofelectrica//eakage problems, mus/ be inspectedfor electrical leakage at least quarterly and replaced when necessmy. This leakage testing will be verified during the exercise, through documentation submilled in 1he ALC and/or through an SA V Pilgrim EOP Rev. 0 Page 9 of SO 07/27/16

Pllt(IBJM NJIQ .EAB POWER STATION EXEBCJSE- November 16 2016 Opera1ional checks and 1esting ofelectronic dosimelers must be in accordance with the mamifacturer 's insn*uctions and be verified during 1he exercise, through documentation submitted in the ALC and/or through an SA V Monitoring Instruments: All instruments must be inspected, inventoried, and operationally checked before each use. Instruments must be calibrated in accordance with the manufac1urer 's recommendations. Unmodified CD V-700 series instruments and other instruments without a manufacturer 's recommendation must be calibrated annually. }v/odified CD V- 700 instruments must be calibrated in accordance with the recommenda1ion ofthe modification manufacturer. A label indicating such calibration must be on each instrument or calibrated.frequency can be verified by 01her means. Jn addilion, instruments being used 10 measure activity musl have a sticker-affixed to their sides indicating the effective range ofthe readings. The range ofreadings documentation specifies the acceptable range ofreadings that the meter should indicate when it is response-checked using a standard test source.

For F1v1Ts, the instruments must be capable ofmeasuring gamma exposure rates and detecting beta radiation. These instruments must be capable ofmeasuring a range ofactivity and exposure, including radiological protection/ exposure control ofteam members and detection ofactivity on air sample collection media, consistent with the intended use of the instrument and the ORO 's p lans/ procedures. An appropriate radioactive check source must be used to veri.fY proper operational response for each low-range radiation measurement instrument (less than I Rlhr.) andfor high-range instruments when available. If a source is not available fo r a high-range instrument, a procedure must exist 10 operationally test the instrument before entering an area where only a high-range instrument can make usefal readings.

Jn areas where portal monitors are used, the OROs must set up and operationally check the moni10r(s).

The monitor(s) must conform to the standards set forth in 1he Contamination Monitoring Standard for a Portal Monitor Usedfor Emergency Response, FEMA -REP-21 (March 1995) or in accordance with the manufacturer 'srecommendations.

M utual Aid Resources: fjthe incoming resources arrive with their own equipment (i.e., monitors and/ or dosimet1y), they will be evaluated by REP Program standards. FElvlA will not inventory equipment that is not part of the REP Program. fjan agency has a defined role in the REP P lan, Iheyare subject to the planning process and standards, as well as the guidance ofthis Manual.

All ac1ivities must be based on the ORO 's plans/procedures and completed as Ihey would be in an actual emergency, unless noted above or otherwise specified in the Ex1ent-oj- Play Agreement.

Massachusetts Extent ofPlay Participating facilities will demonstrate that equipment, maps, displays, monitoring instruments, dosimetry, Kl and other supplies are adequate and sufficient to support the emergency response. FEMA will provide copies of the Annual Letter of Certification to evaluators as documentation of quarterly inventory and operational checks .

Two MA NIAT Field Teams will be dispatched from the Pilgrim EOF in accordance with Section D.4 of the NIAT Handbook. Controller messages will provide simulated monitoring data provided from the plant. Evaluation ofNIAT Field Teams were evaluated by FEMA during Seabrook Graded Exercise on April 5, 2016. NIAT Field Teams will use Pilgrim exercises for practice.

Pilgrim EOP Rev. 0 Page 10 of 50 07/27116

PU ,GBTM NJJ<;J,EAB POWER STATION EXEBQSE- Noycmher 16. 2016 Note: If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator wil l inform the MEMA Controller. After an "on the spot" training by the local or State representative, the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day.

Pilirim EOP Rev. 0 Page II of 50 07127/16

PU ,GBIM NUCJ,EAB POWER STATION EXEBCJSE- Noyember 16. 2016 EVA Ll!A UO N A Rf:A 2

• frecquriqnqrv qndlqr prqtemw: Actiqn Dedsiqn-Mqkjno Sub-element 2.a -Emergency Worker Exposure Control Intent This sub-element isderivedjrom NUREG-0654/ FEMA-REP-I , which requires thatOjfsite Response Organizations (OROs) have the capability to assess and control the radiation exposure received by emergency workers and have a decision chain in place, as specified in the ORO 's plans/procedures, to authorize emergency worker exposure limits to be exceededfor specific missions.

Radiation exposure limitsfor emergency workers are the recommended accumulated dose limits or exposure rates that emergency workers may be permilled to incur during an emergency. These limits include any pre-established administrative reporting limits (that take into consideration Total Effective Dose Equivalent or organ-specific limits) identified in the ORO 's plans/procedures.

Criterion 2. a.1: OR Os use a decision-making process, considering relevant fadors and appropriate coordination, to ensure that an exposure control system, induding the use ofKl, is in place for emergency workers, including provisions to authorize radiation exposure in excess ofadministrative limits or protective action guides. (NUREG-0654/FEMA-REP-l, C. 6.f; K.3. a;K.4)

Extent ofPlay OROs authorized to send emergency workers into the plume exposure pathway EPZ must demonstrate a capability to comply with emergency worker exposure limits based on their emergency plans/procedures.

Participating OROs must demonstrate the capability to make decisions concerning the authorization of exposure levels in excess ofpre-authorized levels and to the number ofemergency workers receiving radiation dose above pre-authorized levels. This would include p roviding Kl and dosimetry in a timely manner to emergency workers dispatched onsite to support plant incident assessment and mitigating actions, in accordance with respective plans/procedures.

As appropriate, OROs must demonstrate the capability to make decisions on the distribution and administration ofKl as a protective measure for emergency workers, based on their 's plan/procedures or projected thyroid dose comparedwith the established Protective Action Guides (PA Gs) for Kl administration.

A ll activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or othen vise specified in the extent ofplay agreement.

Massachusetts Extent ofPlay Protective action decisions are demonstrated at the Massachusetts State EOC based upon information provided from the EOF.

MDPH Radiation Contro l Program EOF staff w ill analyze utility, field team and meteorological date provided at the EOF to make a recommendation to the State EOC for their consideration in making protective action decisions .

Level l or Level 2 Findings: NIA Pilgrim EOP Rev. 0 Pace 12 of SO 07/27116

PU ,GBCM NJ JQ ,EAB POWER STATION EXEBQSE-Noyemher 16. 2016 Sub-element 2.b. -Radiological Assessment, Protective Action Recommendations and Precautionary and/or Protective Action Decisions (or the Plume Phase ofthe Emergency Intent This sub-element is derived from NUREG-0654/FEMA-REP-l, which requires that Offsite Response Organizations (ORO) have the capability to independently project integrated dose from projected or actual dose rates and compare these estimates to the PA Gs.

OROs must have the capability to choose, among a range ofprotective actions, those most appropriate in a given emergency. OROs base these choices on PA Gs from their plans/procedures or EPA 's Manual of Protective Action Guides and Protective Actions for Nuclear Incidents and other criteria, such as plant conditions, licensee PARs, coordination ofprecautionary and/or protective action decisions with other politicaljurisdictions (e.g. , other affected OROs and incident command), availability ofin-place shelter, weather conditions, and situations, to include HAB incidents, the threat posed by the specific hostile action, the affiliated response and the effect ofan evacuation on the threat response effort, that create higher than normal riskfrom general population evacuation.

Criterion 2. b.1: AppropriaJe protective action recommendations (PARs) are based on available injormaJion on plant conditions, field monitoring data, and licensee and ORO dose projections, as well as knowledge of onsite and offsite environmental conditions. (NUREG-0654/FEMA-REP-l, J.JOandSupplement 3)

Extent ofPlay During the initial stage ofthe emergency response.following notification ofplant conditions that may warrant ojfsite protective actions, the ORO must demonstrate the capability to use appropriate means, described in the plan/procedures to develop protective action recommendations (PAR) for decision-makers based on available information and recommendations providedfrom the licensee, as well as.field monitoring data ifavailable. The ORO must also consider any release and meteorological data provided by the licensee.

The ORO must demonstrate a reliable capability to independently validate dose projections. The types of calculations to be demonstrated depend on the data available and the needfor assessments to support the PARs must be appropriate to the scenario. In all cases, calculation ofprojected dose must be demonstrated. Projected doses must be related to quantities and units of the PA G to which they will be compared. PARs must be promptly transmilted to decision -makers in a prearrangedformat.

When the licensee and ORO projected doses differ by more than a factor of I 0, the ORO and licensee must determine the source ofthe difference by discussing input data and assumptions, using different models, or exploring possible reasons. Resolution ofthese differences must be incorporated into the PAR iftimely and appropriate. The ORO must demonstrate the capability to use any additional data to re.fine projected doses and exposure rates and revise the associated PARs.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent of Play Demonstration will be in accordance with the NlAT Handbook. The MDPH Dose Assessment Coordinator at the EOF will independently verify dose projections performed by the Utility.

Pilgrim EOP Rev. 0 Page 13 of SO 07/27116

PIT,GBIM NUCJ ,EAR POWER STATION EXEBCJSE - Nnyember I 6. 2016 The State EOC decision-making team will evaluate the protective action recommendations of the NIA T Accident Assessment Team and develop appropriate protective action decisions.

Protective action recommendations will be made in accordance with the MARERP and NlAT Handbook.

Level land Level 2 Findings: NIA Criterion 2. b. 2: A decision-making process involving consideration ofappropriaJe factors and necessary coordination is used to make precautionary and/or protective action decisions (PA.DJ for the general public (including the recommendation for the use of Kl, if ORO policy).

(NUREG-0654/FEMA-REP-l, A -3; C-4, 6; D-4; J.9, 10.e,f, m)

Extent ofPlay Ojfsite Response Organizations (ORO) must have 1he capability to make bolh initial and subsequent precautionary and/or protective action decisions. OROs must demonstrate the capability to make initial precautionary and/or protective action decisions ina timely manner appropriate to the incident, based on informa1ionfrom the licensee, assessment ofplant s1a1US andpotential or ac/Ual releases, other available iriformation rela1ed10 the incident, inputfrom appropriate OROau1horities (e.g. JncidentCommand), and P ARsfrom the utility and ORO staff Jn addi1ion, a subsequent or alternate precautionary and/or protective action decision may be appropria1e ifvarious conditions (e.g. an HAB incident, weather, release timing and magnitude) pose undue risk to an evacuation, or ifevacuation may disrupt the efforts to respond to a hostile action.

OROs must demonstrate the ability to obtain supplemental resources (e.g. mutual aid) necessary to implement a precauiionary and/or protective action decision iflocal Jaw enforcement, fire service, HAZMAT, and emergency medical resources are used lo augment response 10 1he NP P site or other key infrastructure.

Dose assessment personnel may provide additional PARs based on the subsequent dose p rojections, fie Id monitoring data, or iriformalion on plant condilions. Jn addition, incidenl command must provide input regarding consideralionsfor subsequent PARs based on the magnitude oflhe ongoing 1hreat, the response, and/or sile condi1ions. The decision-makers must demonstrale lhe capability to change prolective actions based on the combination ofal/ 1hese factors.

If1he ORO has determined that KI wi/J be used as a protective measure for the general public under ojfsite plans/procedures, then it must demonstrate the capability to make decisions on the distribUlion and administration ofKI lo supplement sheltering and evacuation. This decision must be based on the ORO 's plans/procedures or projected thyroid dose compared with the established PAGfor KI administration. The KI decision-makingprocess must involve close coordination with appropriate assessment and decision-making staff Ifmore than one ORO is involved in decision-making, al/ appropriate OROs must communicale and coordinate precautionary and/or protective action decisions with each other. Jn addi1ion, decisions must be coordinated! communicated with incident command. OROs mus/ demonstrate the capability to communicale the results ofdecisions to al/ the affected locations.

Al/ activities must *be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Pilgrim EOP Rev. 0 Page 14 of 50 07n7/16

PD ,GBIM NJTCU:A B POWER STATION EXERCISE- Noyemher 16. 2016 Massachusetts Extent ofPlay Protective action decisions are demonstrated at the Massachusetts State EOC based upon information provided by the EOF. MEMA and MDPH Radiation Control Program staff will analyze the Util ity, field monitoring and meteorological data provided at the EOF to make a recommendation to the State EOC for their consideration in making protective action decisions .

Level I or Level 2 Findings: /A Pilgrim EOP Rev. 0 Page 15 of 50 07127116

PO ,GRIM NUQR<\B POWER STATION FXERCJSE- November 16. 2016 Sub-element 2.c-Precautionary and/or Protective Action Decision Consideration for the Protection of Persons with Disabilities and Access/Functional Needs Intent This sub-element is derived.from NUREG-0654/FEMA-REP-1 , which requires that Offs ite Response Organizations (ORO) have the capability to determine precautionary and/or protective action decisions, including evacuation, sheltering and use ofpotassium iodide (Kl), ifapplicable,for groups ofpersons with disabilities and accesslfimctional needs(e.g., hospitals, nursing homes, correctionalfacilities, schools, licensed day care, mobility impaired individuals, and transportation-dependent individuals). The focus is on those groups ofpersons with disabilities and access/functional needs that are or potentia//ywi// be affected by a radiological release from a nuclearpower plant.

Criterion 2.c.l: Precautionary and/or Protective action decisions are made, as appropriate, for groups of persons with disabilities and access/functional needs. (NUREG-0654/FEMA-REP-1, D.4; J.9; J.10.d, e)

Extent ofPlay Usually it is appropriate to implement evacuation in areas where doses are projected to exceed the lower end of the range ofPA Gs, exceptfor incidents where there is a high-risk environmental condition or where high-risk groups (e.g. , the immobile or infirm) are involved. In these cases.fa ctors must be considered include weather conditions, shelter availability, availability oftransportation assets, risk of evacuation vs. risk.from the avoided dose, and precautionary school evacuations. Jn addition, decisions must be coordinated/ communicated with the incident command. In situations where an insritutionalized population cannor be evacuared, the ORO mus/ consider use ofKl.

Applicable OROs must demonstrate the capability to alert and notify all public school systems/districts of emergency conditions that are expected to or may necessitate protective actions for students.

Demonstration requires that the OROs actually contact public school systems/districts during The exercise.

The OROs musr demonstrate how the decision-making process takes those with disabilities and access/functional needs (e.g. , nursing homes, correctionalfacilities, licensed day cares, mobility-impaired individuals, and transportarion-dependent individuals) into account.

In accordance with plans/procedures, OROs and/or officials ofpublic school systems/districts must demonsn*ate the capability ro make prompt decisions on protective actions for students. The decision-makingprocess, including any preplannedstrategiesjor protecrive actions for that ECL, must consider the locarion ofstudents at the time (e.g. , whether the students are still at home, enroute to school, or at school).

Since other agencies place requirements on hospitals ro prepare f or contaminated patients. the REP Program has no need to evaluate hospitals in the EPZ That need to evacuate, or the facilities that are receiving These evacuees, nor does the ORO have The responsibility to provide training or dosimetry 10 these hospitals/facilities. Addirionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.

A ll activities associated must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Pilgrim EOP Rev. 0 Page 16 of 50 07/27/16

PIT.GRIM NI JCJ .EAR POWER STATION EXERCISE - Ngyember 16. 2016 MassachusettsExtentofPlay Protective action decisions, including those for groups of persons with disabilities and access/functional needs, are demonstrated at the Massachusetts State EOC based upon information prov ided by MEMA and MDPH Radiation Control Program staff at the EOF. MEMA and MDPH Radiation Control Program staff will analyze Utility, fie ld team and meteorological data provided at the EOF to make a recommendation to the State EOC fo r their consideration in making protection action decisions.

Level I or Level 2 Findings: N/A Pilgrim EOP Rev. 0 Page 17 of SO 07/27116

PU,GBIM NI TCJ,EA B POWER STATION EXEBCJSE - Noyemher 16. 2016 Sub-element 2d - Radiolo 'ca/Assessment and Decision-Makin Intent This sub-element is derivedfrom NUREG-0654/FEMA-REP-J , which requires that Ojfsite Response Organizations (ORO) have the means to assess the radiological consequences for the ingestion exposure pathway, relate them to the appropriate PA Gs, and make timely, appropriate protective action decisions to mitigate exposure from the pathway. During an accident at a nuclear power plant, a release of radioactive material may contaminate water supplies and agriculturalproducts in the surrounding areas.

Any such contamination would likely occur during the plume phase ofthe accident and, depending on the nature ofthe release, could impact the ingestion pathwayfor weeks or years.

Criterion 2.dl: R adiological consequ ences for the ingestion pathway are assessed and appropriate protective action decisions are made based on the ORO's planning criteria.

(NUREG-0654/FEMA-REP-1, A.3; Cl, 4; D.4; J.9, 11)

Extent ofPlay Ojfsite Response Organizations (ORO) are expected to rake precautionary actions to protectfood and water supplies, or to minimize exposure to potentially contaminated water andfood, in accordance with their respective plans/procedures. Often OROs initiate such actions based on criteria related to the facility's Emergency Classification Levels (ECL). Such actions may include recommendations to place milk animals on stored.feed and to use protected water supplies.

The ORO must use its procedures to assess the radiological consequences ofa release on the food and water supplies, such as the development ofa samplingplan. The ORO 's assessment must include the evaluation of the radiological analyses ofrepresentative samples ofwater,food, and other ingestible substances oflocal interestfrom potentially impacted areas; characterization ofthe releases.from the facility; and the extent of areas potentially impacted by the release. During this assessment, OROs must consider the use of agricultural and watershed data within the 50-mile EPZ. The radiological impacts on the food and water must rhen be compared to the appropriate ingestion PA Gs contained in the ORO's plan/procedures. The plans/procedures contain PA Gs based on specific dose commitment criteria or on criteria as recommended by current Food and Drug A dministration guidance. Timely and appropriate recommendations must be provided to the ORO decision-makers group for implementation decisions. OROs may also include a comparison oftaking or not taking a given action on the resultant ingestion pathway dose commitments.

The ORO must demonstrate timely decisions to minimize radiological impactsfrom the ingestion pathway, based on the given assessments and other information. Any such decisions must be communicated and, to the extentpractical, coordinatedwith neighboring and local OROs. These decisions include tracking agriculturalproducts entering and leaving the EPZ. Demonstration ofplans andprocedures which use traffic access control points to track agriculturalproducts enteringand leaving the EP Z may be conducted through interview. OROs will use Federal resources, as identified in the N uclear/Radiological Incident Annex ofthe NRF and other resources (e.g. , compacts, nuclear insurers), as necessary. Evaluation ofthis criterion will take into consideration the level ofFedera/and other resources participating.

A ll activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent of Play This sub-element will not be demonstrated during this exercise.

Level 1 or Level 2 Findings: N/A Pilgnm EOP Rev. 0 Page 18 ol 50 07727116

fU ,QBIM NJJQ ,EAR POWER STATION EXERCJSE- Noyemher 16 2016 Concernin Post-Plume Phase elocation Re-en Intent This sub-element is derived.from NUREG-0654/FEMA -REP-I, which requires thatOffsite Response Organizations (ORO) have the capability to make decisions on post-plume relocation, re-entry, and return ofthe general public. These decisions are essential for the protection ofthe public.from the direct long-term exposure to deposited radioactive materials from a severe accident at a nuclear power plant.

Criterion 2. e. I: Timely post-plume phase relocation, re-entry, and return decisions are mJJde and coordinated as appropriate, based on assessments ofthe radiological conditions and criteria in the OR O's plan and/or procedures. (NUREG-0654/FEMA-REP-1, LIO; J.9; K.3.a; M.l)

Extent ofPlay Relocation: OROs must demonstrate the capability to estimate integrated dose in contaminated areas and compare these estimates with PA Gs; apply decision criteriaf or relocation ofthose individuals in the general public who have not been evacuated, buiwhere actual or projected doses are in excess ofrelocationPAGs; and control access to evacuated and restricted areas. OROs will make decisions for relocating members of the evacuatedpublic who lived in areas that now have residual radiation levels in excess ofthe PA Gs.

Determination ofareas to be restricted must be based on factors such as the mix ofradionuclides in deposited mate rials, calculated exposure rates vs. the PA Gs, and analyses ofvegetation and soil.field samples.

Re-entry: Decisions must be made on the location ofcontrol points and policies regarding access and exposure controlfor emergency workers and members ofthe general public who need to temporarily enter the evacuated area to perform specific tasks or missions.

Examples ofcontrol procedures are the assignment of, or checking/or, direct-reading and permanent record dosimetry for emergency workers; questions regarding an individual 's objectives, locations expected to be visited and associated time frames ; availability ofmaps and plots ofradiation exposure rates; and advice on areas to avoid. Control procedures also include monitoring of individuals, vehicles, and equipment; the implementation ofdecision criteria regarding decontamination; and proper disposition ofemergency worker dosimetry and maintenance ofemergency worker radiation exposure records.

Responsible OROs must demonstrate the capability to develop a strategyfor authorized re-entry of individuals into the restricted zone(s), based on established decision criteria. OROs must demonstrate the capability to modify those policies for security purposes (e.g., police patrols), maintenance ofessential services (e .g. ,fire protection and utilities), and other critical.functions. They must demonstrate the capability to use decision-making criteria in allowing access to the restricted zone by the public for various reasons, such as to maintain property (e.g. , to care for farm animals or secure machinery for storage), or retrieve important possessions. Coordinated policies for access and exposure control must be developed among all agencies with roles to perform in the restricted zone(s). OROs must demonstrate the capability to establish policies for provision ofdosimetry to all individuals allowed to re-enter the restricted zone(s). The extent that OROs need to develop policies on re-ent1y will be determined by scenario events.

Pilgrim E:OP Rev. 0 Page 19 of 50 07/27/16

PU ,GRIM NJ JQ,EAB fOWEB SIAJION EXERCISE- N9yemher 16 2016 Return: OROs must demonstrate the capability to implement policies concerning return ofmembers of the public to areas that were evacuated during the plume phase (i.e., permitting populations that were previously evacuated to reoccupy their homes and businesses on an unrestricted basis). OROs must base their decisions on environmental data and political boundaries or physical/geologicalfeatures, which allow identification ofthe boundaries ofareas to which members ofthe general public may return.

Return is permiued to the boundary ofthe restricted area(s) that is based on the relocation PAG.

Other factors that the ORO must consider in decision-making include conditions that permit the cancellation ofthe Emergency Classification Level and the relaxation ofassociated restrictive measures.

OROs must base return recommendations on measurements ofradiation.from ground deposition. OROs must have the capability to identify services andfacilities that require restoration within a few days and to identify the procedures and resources/or their restoration. Examples ofthese services andfacilities are medical and social services, utilities, roads, schools, and intermediate-term housing/or relocated persons.

All activities must be based on the ORO 's plans/procedures and completed as rhey would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent of Play This sub-element will not be demonstrated during this exercise.

Level 1 or Level 2 Findings: /A Pllgtlm t!6P ltev. 6 Page %6 of36

PU ,GBIM NITCJ,EAB POWER STATION EXEBCJSE- Noyember 16. 2016 EVA/ I TA TTON A REA 1* P,qtgctive Actiqn Tmplemenmtiqn Sub-element 3.a-Jmplementation of Emergency Worker Exposure Control Intent This sub-element is derivedfrom NUREG-0654/FElvfA-REP-I, which requires thatOROs have the capability to provide for the following: distribution, use, collection, and processing ofdirect-reading dosimetry and permanent record dosimetry; reading ofdirect-reading dosimetry by emergency workers at appropriate frequencies ; maintaining a radiation dose recordfor each emergency worker; establishing a decision chain or authorization procedure for emergency workers to incur radiation exposures in excess of protective action guides, and the capability to provide Kl/or emergency workers, always applying the A LARA (As Low As is Reasonably Achievable) principle as appropriate.

Criterion 3.a.J: The OR Os issue appropriate dosimetry, Kl, and procedures, and manage radiological exposure to emergency workers in accordance with the plans/procedures.

Emergency workers periodically and at the end ofeach mission read their dosimeters and record the readings on the appropriate exposure record or chart OR Os maintain appropriate recordkeeping ofthe administration ofKl to emergency workers. (NUREG-0654/FEMA -REP-1, K.3.a, b; K. 4)

Extent ofPlay OROs must demonstrate the capability to provide emergency workers (including supplemental resources) with the appropriate direct-reading and permanent record dosimetry, dosimeter chargers, Kl, and instructions on the use of these items. For evaluation purposes, appropriate direct-reading dosimetry is defined as dosimetry that allows individual(s) to read the administrative reporting limits that are pre-established at a level low enough to consider subsequent calculation ofTotal Effective Dose Equivalent and maximum exposure limits,for those emergency workers involved in life saving activities contained in the ORO 's plans/procedures.

Each emergency worker must have the basic knowledge ofradiation exposure limits as specified in the ORO's plans/procedures. Ifsupplemental resources are used, they must be provided with just-in-time training to ensure basic knowledge ofradiation exposure control. Emergency workers must demonstrate procedures to monitor and record dosimeter readings and manage radiological exposure control.

During a plume phase exercise, emergency workers must demonstrate the procedures to be followed when administrative exposure limits and turn-back values are reached. The emergency worker must report accumulated exposures during the exercise as indicated in the plans/procedures. OROs must demonstrate the actions described in the plans/procedures by determiningwhether to replace the worker, authorize the worker to incur additional exposures, or to take other actions. Ifexercise play does not require emergency workers to seek authorizations for additional exposure, evaluators must interview at least two emergency workers to determine their knowledge ofwhom to contact in case authorization is needed, and at what exposure levels. Workers may use any available resources (e.g., written procedures and/or co-workers) in providing responses.

A lthough it is desirable for all emergency workers to each have a direct-reading dosimeter, there may be situations where team members will be in close proximity to each other during the entire mission. In such cases, adequate control ofexposure can be affected achievedfor all team members using one dosimeter worn by the team leader. Emergency workers who are assigned to low exposure rate fixed facilities, (e.g. , EOCs and communications center within the EPZ, reception centers, and counting laboratories)

Pilgrim EOP Rev. 0 Page 21of50 07127116

PU ,GRIM NUCJ,EAB POWER STATTON f.XEBCJSE- Noyemher 16. 2016 may have individual direct-reading dosimeters or they may be monitored using group dosimetry (i.e.,

direct-reading dosimeters strategically placed in the work area). Each team member must still have his or her own permanent record dosimetry. Individuals authorized by the ORO to reenter an evacuated area during the plume (emergency) phase, must be limited to the lowest radiological exposure commensurate with completing their missions.

OROs may have administrative limits lower than EPA-400-R-92-001 dose limits for emergency workers performing various services (e.g. , lifesaving, p rotection ofvaluable property, all activities). ORO must ensure that the process used to seek authorizations for exceeding dose limits does nor negatively impact the capability to respond to an incident where lifesaving and/or protection ofvaluable p roperty may require an urgent response.

OROs must demonstrate the capability to accomplish distribution ofKl to emergency workers consistent with decisions made. OROs must have the capability to develop and maintain lists ofemergency workers who have ingested Kl, including documentation ofthe date(s) and time(s) they did so. Ingestion ofKl recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion ofKl shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using Kl fo r those advised to take it. Emergency workers must demonstrate basic knowledge ofprocedures for using Kl whether or not 1he scenario drives the implementation ofKl use. This can be accomplished by an interview wi1h an evaluator.

All activities must be based on the ORO 's plans/p rocedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent of Play EPZ EOCs: Dosimetry packets will be issued to two emergency workers in each EPZ EOC. Actual distribution and ingestion of Kl will not occur. Empty Kl tablet containers (small zip-lock bags) will be included in the dosimetry packets for emergency workers. Knowledge of the use of dosimetry and Kl will be demonstrated throusJI an interview of these two individuals by the FEMA Evaluator.

Region II EOC: Extra Dosunetry packets and Kl are stored at this facility . No staff from this facility responds to the EPZ. Massachusetts State Police are used for compensatory response not Region II personnel. There will not be a dosimetry briefing at this location.

Level l or Level 2 Findings: NIA Note: If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an "on the spot" training by the local or State representative, the FEMA Evaluator will provide anotheropportunity to re-demonstrate the activity that day.

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PU ,GRIM Nl!CJiEAB POWER STATION EXERCISE - Noyember 16. 20 16 S ub-element 3. b-lmelementaJion o(KI Decision (or Institutionalized Individuals and the General Public Intent This sub-element isderivedfrom NUREG-0654/FEMA-REP-l , which requires rhat Ojfsite Response Organizations (ORO) have the capability to provide Kl institutionalized individuals, and, if in the plans/procedures, to the general public for whom immediate evacuation may nor be feasible, ve1y difficult, or significantly delayed. While ii is necessary for OROs 10 have rhe capability to provide Kl to institutionalized individuals, providing Kl to the general public is an ORO option and must be reflected in ORO 's plans/procedures. Provisions should include the availability ofadequate quantities, storage, and means ofthe distribution ofKl.

Criterion 3. b. l: KI and approp riate instructions are available if a decision to recommend use of KI is made. AppropriaJe record keeping of the administration of KI f or institutionalized individuals is maintained (NUREG-0654/FEMA -REP-1, J. 10.e,j)

Extent of Play Ojfsite Response Organizations (ORO) must dem onstrate the capability to make Kl available to institutionalized individuals, and, where providedfor in the ORO plans/procedures, to members ofthe genera/public. OROs must demonstrate the capability to accomplish distribution ofKl consistentwith decisions made. OROs must have the capability to develop and maintain lists of institutionalized individuals who have ingested Kl, including documentation ofthe date(s) and time(s) they were instructed to ingest Kl. Ingestion ofKl recommended by the designated ORO health official is voluntary. For evaluation purposes, the actual ingestion ofKl shall not be performed. OROs must demonstrate the capability to formulate and disseminate instructions on using Klfor those advised 10 take it.

Ifa recommendation is made for the general public to take Kl, appropriate ieformation must be provided 10 the public by the means ofnotificarion specified in the ORO 's plans/procedures.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

MassachusettsExtentofPlay Schoo ls, day cares, and special fac ility staff who administer Kl will be interviewed out-of-sequence by the FEMA Evaluator (see page 2 ofEOP). The FEMA Evaluator will check the availability of adequate quantities, storage, and means ofKJ distribution.

R egion II EO C: Extra Dosimetry packets and Kl are stored at this facility. No staff from this facility responds to the EPZ. Massachusetts State Police are used for compensatory response not Region II personnel. There will not be a Kl briefmg at this location.

Level l or Level 2 Findings: N/A Note: If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an "on the spot" training by the local or State representative, the FEMAEvaluatorwill provide another opportunity to re-demonstrate the activity that day.

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PU,GRIM NJJQ,EAB POWER SJ,UJON EXERCJSE- Noyember 16. 2016 Sub-element 3.c--lmplementation of Precautionary and/or Protective Actions for Persons with Disabilities andAccess/Functional Needs Intent This sub-element is derived.from NUREG-0654/FEMA -REP-1, which requires that Ojfsite Response Organizations (ORO) have the capability to implement precautionary and/or p rotective action decisions, including evacuation and/or sheltering,for all persons w ith disabilities and access/functional needs. The focus is on those persons with disabilities and access/functional needs that are (or potentially will be) affected by a radiological release from a nuclear power plant.

Criterion 3. c.1: Precautionary and/or protective action decisions are implementedfor persons with disabilities and access/functional needs other than schools within areas subject to protective actions. (NVREG-0654/FEMA-REP-l, J.10. c, d, e, g)

Extent ofPlay Applicable OROs must de monstrate the capability to alert and notify (i.e., provide protective action recommendations and emergency iriformarion and instructions to) persons with disabilities and access/functional needs, including hospitals/medical facilities, licensed day cares, nursing homes, correctionalfacilities, mobility impaired and transportation dependent individuals. OROs must demonstrate the capability to provide for p ersons with disabilities and access/functional needs in accordance with plans/procedures.

Contact with persons with disabilities and access/functional needs and reception faci lities may be actual or simulated, as agreed to in the Extent ofPlay. Some contacts with transportation providers must be actually contacted. as negotiated in the extent ofplay. A ll actual and simulated contacts should be logged Since other agencies place requirements on hospitals to prepare for contaminatedpatients, the REP Program has no need to evaluate hospitals in the EPZ that need to evacuate, or the facilities that are receiving these evacuees, nor does the ORO have the responsibility to provide training or dosimetry to these hospitals/facilities. Additionally, hospital evacuation plans do not need to be reviewed or tested by the REP program.

A ll activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent ofPlay SEOC: The U.S . Coast Guard representative will establ ish contact with the District Command Center and communicate with them throughout the exercise. No Broadcasting over the Urgent Marine Information Broadcast will occur only simulation . Only initial communication with the Captain of the Port will be established thereafter contact w ill be simulated.

Region II : Initial calls to all Transportation Providers will be made to verify telephone number and contact person . A Controller message will refer to matrix to provide the number of vehicles and drivers available for exercise play. No vehicles or personnel will be mobilized. A list of the Transportation Providers will be provided to the FEMA Evaluator.

Region II Special Needs Coordinator and staff (CMED) will demonstrate all appropriate communications with EPZ community EOC staff and simulate coordination of bed space assignment for evacuating

PIJ ,GBIM NJTCLEAR POWER STATION EXEBCJSE- Noyember 16 2016 nursing home patients and hospital patients, although actual evacuation of special facilities will not occur.

A Controller message will provide the default number of estimated bed spaces in host hospitals. All contact with hospitals will be simulated.

EPZ EOCs: All special facilities will receive initial contact. Follow-up calls will be simulated and logged. Participating special facilities will be interviewed out of sequence by a FEMA Evaluator (see page 2 of the EOP).

EPZ EOCs: The list of persons with disabilities and access/functional needs will be shown to the FEMA evaluator; however, the information is confidential and copies will not be provided to the evaluator. Staff wi ll simulate and log calls to the individuals on the list that have identified themselves as needing assistance during an emergency.

Level l or Level 2 Findings: /A Criterion 3.c.2: OR Os/School officials implement precautionary/protective actions for schools.

(NUREG-0654/FEMA -REP-1, J.10.c, d, e, g)

Extent ofPlay School systems/districts (these include public and private schools, kindergartens, and preschools) must demonstrate the ability to implement precautionary and/or p rotective action decisionsfor students. The demonstration must be made as follows: Each school system/district within the 10 mile EPZ must demonstrate implementation ofprotective actions. A I least one school per affected system/district must par1icipa1e in the demonstration. Canceling the school day, dismissing early, or sheltering in place must be simulated by describing to evalua1ors the procedures /hat would be followed Ifevacuation is the implemen1edprotective action. all activities to coordinate and complete /he evacuation ofstudents to reception centers, congregate care centers, or host schools may actually be demonstrated or accomplished through an interview process.

Ifaccomplished through an interview, appropriate schoolpersonnel including decision-making officials (e.g. , schools ' superintendenJ/principals and transpor1ation director/bus dispatchers) , and at least one bus driver (and the bus driver 's escort, ifapplicable) must be available to demonstrate knowledge oftheir role(s) in the evacuation ofschool children. Communications capabilities between school officials and lhe buses, ifrequired by 1he plans/procedures, must be verified Officials ofthe school system(s) must demonstrate the capability to develop and provide timely information to OROsfor use in messages 10 parents, Jhe general public, and the media on the status of pro1ec1ive aclionsfor schools.

Ifa school facility has emergency plans as a condition oflicensing, those plans may be submitted to FEMA review in place ofdemonstration or inlerview p ursuanl to the ORO 's p lans/procedures as negotiated in the Extent ofPlay Agreement.

All activities must be based on the ORO 's plans/procedures and completed, as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

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PU,GBTMNIIQ.EAB POWER STATION f:XEBCISE-Noyemher 16. 2016 Region 0 EOC: The MEMA Region II Special Needs Coordinator, in an interview with the FEMA Evaluator, will provide a list of schools located outside the EPZ with students who reside within the EPZ.

Calls to schools outside the EPZ will be simulated and logged.

EPZ EOCs: Initial notification will be made to all schools and day care centers.

EPZ Schools: Participating facilities were visited out of sequence by a FEMA Evaluator in 2016, who interviewed key players (and if the site ' s plan calls for KI, responsible staff). See page 2 of Extent of Play for list Day Care Centers: Participating facilities were visited out of sequence by a FEMA Evaluator, who interviewed key players (and if the site' s plan calls for KI, responsible staff). See page 2 of Extent of Play for list.

Level 1 or Level 2 Findings: /A Pil&rim EOP Rev. 0 Page 26 of SO 07/27/16

PU ,GRJM NJJCJ.EAB POWER STATION EXERCJSE- Noyemher 16. 2016 Sub-element 3.d - Im lementation o Tra 1c and Access Control Intent This sub-element isderivedfromNUREG*0654/FEJvfA -REP-l, which requires thatOffsite Response Organizations (ORO) have the capability to implement protective action plans/procedures, including relocation and restriction ofaccess to evacuated/sheltered areas. This sub-element focuses on selecting, establishing, and staffing oftraffic and access control points and removal ofimpediments to the flow of evacuation traffic.

Criterion 3.dl: Appropriate traffic and access control is established Accurate instructions are provided to traffic and access control personnel (NUREG-0654/FEMA-REP-l, A.3; C.J, 4; J.10.g,j)

Extent ofPlay OROs must demonstrate the capability to select, establish, and staffappropriate traffic and access control points consistent with current conditions and protective action decisions (e.g. , evacuating, sheltering, and relocation), in a timely manner. OROs must demonstrate the capability 10 provide instructions to traffic and access control staffon actions to take when modifications in protective action strategies necessitate changes in evacuation patterns or in the area(s) where access is controlled.

Traffic and access control staffmust demonstrate accurate knowledge oftheir roles and responsibilities, including verifying emergency worker identification and access authorization to the affected areas, as per the extent ofplay agreement. These capabilities may be demonstrated by actual deployment or by interview, in accordance with the extent ofplay agreement.

In instances where OROs lack authority necessary 10 control access by certain types of traffic (e.g. , rail, water, and air traffic), they must demonstrate the capability to contact the State or Federal agencies that have the needed authority, as agreed upon by the extent ofplay agreement.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent ofPlay State EOCs: Contact with water, rail and air authorities are demonstrated at the State EOC.

EPZ EOCs: EOCs will demonstrate the ability to direct and monitor traffic control operations within their jurisdictions through discussions with the evaluator. The local EOC highway and/or Law Enforcement representative will participate in a discussion of procedures and resources available for traffic control. No personnel or equipment will be deployed to field locations.

Level I or Level 2 Findings: NIA Note: If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an "on the spot" training by the local or State representative, the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day.

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PU ,QBJM NI!CJ ,EAB POWER STATION EXERCISE- Noyemher 16 2016 Criterion 3.d2: Impediments to evacuation are identified and resolved (NUREG-0654/FEMA-REP-1, J.10.k)

Extent ofPlay 0 ROs must demonstrate the capability to identify and take appropriate actions concerning impediments to evacuations. In demonstrating this capability, the impediment must remain in place during the evacuation long enough that re-routing oftraffic is required and must also result in demonstration of de cision-making and coordination with the JIC to communicate the alternate route to evacuees.

When, due to specifics of the scenario or jurisdiction, the impediment cannot be located on an evacuation route, it must be located so as to impact the evacuation. When not possible, actual dispatch of resources need not be physically demonstrated; however, all contacts, actual or simulated, should be logged.

A ll activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or othenvise specified in the extent ofplay agreemenL Massachusetts Extent ofPlay Each EPZ Local EOC will demonstrate rerouting of traffic following a traffic impediment through an interview with the FEMA Evaluator. No personnel or equipment will be dispatched to the simulated acc ident scene. One EPZ co mmunity will be have an impediment that is likely to cause lengthy rerouting of traffic along the evacuation route, this Local EOC will communicate this information to MEMA Region II in order for this information to be passed to the State EOC and the JlC. MA will demonstrate only one Local EOC will demonstrate the coordination with the JIC to communicate the alternate route to evacuees.

Note : If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an " on the spot" training by the local or State representative, the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day.

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Pil ,GRIM NTTCJ,f;AR POWER STATION EXERCJSE- Noyember 16 2016 Sub-element3.e-l lementation o Jnnestion Decisions Intent This sub-element isderivedfrom NUREG-0654/FEMA-REP-l , which requires thatOROs have the capability to implement protective actions, based on criteria recommended by current Food and Drug Administration guidance.for the ingestion exposure pathway EPZ (i.e. , the area within an approximate 50-mile radius ofthe nuclear power plant). This sub-elementfocuses on those actions requiredfor implementation ofprotective actions.

Criterion 3.e.1: The ORO demonstraJes the availability and appropriaJe use ofadequaJe information regarding waJer, food supplies, milk, and agricultural production within the ingestion exposure paJ/1way emergency planning zone for implementaJion ofprotective actions.

(NUREG-0654/FEMA-REP-1,A.3; Cl, 4; J.11)

Extent ofPlay Applicable OROs must demonstrate the capability to secure and use current information on the locations of dairyfarms, meat andpoultry producers.fisheries.fruit growers, vegetable growers, grain producers.food processingplants, andwater supply intake points to implement protective actions within the EPZ OROs use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex, and other resources (e.g.,

compacts, nuclear insurers) ifavailable. Evaluation ofthis criterion will take into consideration the level of Federal and other resources participating in the exercise.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or othenvise specified in the extent ofplay agreement Massachusetts Extent of Play This criterion will not be demonstrated during this exercise.

Level I or Level 2 Findings: N/A Criterion 3. e.2: AppropriaJe measures, straJegies, and pre-printed instructional material are developedfor implementing protective action decisiotlS for contaminaJedwaJer,foodproducts, milk, and agricultural productiotL (NUREG-0654/FEMA-REP-1, G.1; J.9, 11)

Extent ofPlay OROs must demonstrate the development ofmeasures and strategies fo r implementation ofingestion exposure pathway EPZ protective actions byformulating protective action information for the general public andfood producers and processors. Demonstration ofthis criterion includes either pre-distributed public information material in the ingestion exposure pathway EPZ or the capabilityfor the rapid reproduction and distribution ofappropriate reproduction-ready information and instructions to pre-determined individuals and businesses.

OROs must also demonstrate the capability to control, restrict or prevent distribution ofcontaminated food by commercial sectors. Exercise play must include demonstration efcommunications and coordination among organizations to implement protective actions. Field play ofimplementation activities may be simulated. For example, communications and coordination with agencies responsible for enforcingfood controls within the ingestion exposure pathway EPZ must be demonstrated, but actual communications with food producers and processors may be simulated.

Pilgoim E9P lk< . 9 Psgd9 oFS9 9?127116

PO ,GBIM NJ JCJ ,EAB POWER STATION f:XEBCJSE-Ngyemher 16. 2016 All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent ofPlay This criterion wil l not be demonstrated during this exercise.

Level I or Level 2 Findings: N/A Pilgrim EOP Rev. 0 07/27116

PU,GBIM NJTCJ,EAB POWER STATION EXEBQSE Noyemher 16. 2016 Sub-element 3. - l lementation o Post-Plume Phase Relocatiot Re-ent and Return Decisions Intent This sub-element isderivedfromNUREG-0654/FEMA-REP-l , which requires thatOffsite Response Organizations (ORO) have the capability to implement plans, procedures, and decisionsfor post-plume phase relocation, re-entry, and return. implementation ofthese decisions is essential/or protecting the public from the direct long-term exposure to deposited radioactive materials from a severe accident at a commercial nuclear powerplant.

Criterion 3.f.l: Decisions regarding controlled re-entry, relocation, and return ofindividuals during the post-plume phase are coordinated with appropriate organizations and implemented (NUREG-0654/FEMA -REP-1, E. 7; J.10.j; J.12; K.5.b; M.1, 3)

Exte11t ofPlay Relocatio11: OR Os must demonstrate the capability to coordinate and implement decisions concerning relocation ofindividuals located in radiologically contaminatedareas who were notpreviously evacuated Such individuals must be relocated to an area(s) where radiological contamination will not expose the generalpublic to doses that exceed the relocationPAGs. OROs must also demonstrate the capability to providefor short- or long-term relocation ofevacuees who lived in area(s) that have residual radiation levels above the (first-, second-, and 50-year) PA Gs.

Areas ofconsideration must include the capability ofOROs to communicate with other OROs regarding timing ofactions, notification ofthe population ofprocedures/or relocation, and the notification of, and advice for, evacuated individuals who will be converted to relocation status in situations where they will not be able to return to their homes due to high levels ofcontamination. OROs must also demonstrate the capability to communicate instructions to the public regarding relocation decisions and intermediate-term housing/or relocatedpersons.

Re-entry: OROs must demonstrate the capability to control re-entry and exit ofindividuals who are authorized by the ORO to temporarily re-enter the restricted area during the post-plume (i.e. , intermediate or late) phase to protect them from unnecessary radiation exposure. OROs must also demonstrate the capability to control exit ofvehicles and equipment to control the spread ofcontamination outside the restrictedarea(s). individuals without specific radiological response missions, such as farmers for animal care, essential utility service personnel, or other members ofthe public who must reenter an evacuated area during the post-emergency phase must be limited to the lowest radiological exposure commensurate with completing their missions. Monitoring and de contaminationfacilities will be establishedas appropriate.

Examples ofcontrol procedure subjects are: (1) the assignment of, or checking/or, direct-reading and permanent record dosimetryfor emergency workers: (2) questions regarding the individuals' objective(s),

location(s) expected to be visited. and associated timeframes; (3) maps and plots ofradiation exposure rates; (4) advice on areas to avoid; (5) procedures for exit, including monitoring of individuals, vehicles, and equipment; (6) decision criteria regarding contamination; (7) proper disposition of emergency worker dosimetry; and (8)maintenance ofemergencyworker radiation exposure records.

Return: OROs must demonstrate the capability to implementpolicies concerning return ofmembers ofthe public to areas that were evacuated during the plume phase. OROs must demonstrate the capability to identify and prioritize services andfacilities that require restorption within a few days, and to identify the procedures and resourcesfor their restoration. Examples ofthese services andfacilities are medical and social services, utilities, roads, and schools.

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Pil ,GRIM Nl !CJ,f;AR POWER STATION EXERCJSE- Noyember 16. 2016 Communications among OROsjor relocation, re-entry, and return may be simulated. All simulated or actual contacts must be documented. These discussions may be accomplished ina group setting.

OROs should use Federal resources as identified in 1he NRF Nuclear/Radiological Incidenl Annex, and other resources (e.g. , compacts, nuclear insurers), as necessary, ifavailable. Evalualion oj1his criterion wil/ 1ake into consideration the level ofFederal and other resources participating in the exercise.

All activities must be based on 1he ORO 's plans/p rocedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extenl ofplay agreement.

Massachusetts Extent ofPlay This sub-element will not be demonstrated during this exercise.

Level l or Level 2 Findings: N/A Piigrim £ Of RC\1. 0 Patt 32 Ui 30 07J27Jld

PU ,GBW NJJCJ,EAR POWE R STATION EXE BCJSE - Noyember 16 2016 *'

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• Field Meqwcgment A nd A nqly5j5 S u b-element 4.a - Plu me Phase Field M easucements and A n alvses latent This sub-element is derived.from NUREG-0654/FEMA-REP-l , which requires rhatOjfsite Response Organizations (ORO) have the capabiliry to deploy fie ld teams with rhe equipment, methods, and experrise necessary to determine the location ofairborne radiation and particulare deposition on the ground from an airborne plume. In addirion, NUREG-0654/FEMA-REP- l indicates thatOROs must have the capabiliry to use.field monitoring teams within the p lume exposure pathway EPZ to detect airborne radioiodine in the presence ofnoble gases and radioactive particulate material in the airborne plume. In an incident at a nuclear power p lant, the possible release ofradioactive material may pose a risk to the nearby population and environment. Although incident assessment methods are available to project the extent and magnitude ofa release, these methods are subject to large uncertainties. During an incident, ii is important to collect.field radiological data to help characterize any radiological release.

Adequate equipment and procedures are essential to such.field measurement efforts.

Criterion 4. a. 1: R eserved Criterion 4. a. 2 : Field teams (2 or m ore) ace managed to obtain sufficient information to help ch aracterize the release and to control radiation exposure. (NUREG-0654/FEMA -REP-1, C 1; H. 12;

1. 7, 8, 11; J.10.a)

Extent of Play Responsible Ojfsite Response Organizations (ORO) must demonstrate rhe capabiliry to brief.field monitoring teams on predictedplume location and direction, plume travel speed, and exposure control procedures before deployment. During an HAE incident, the.field team management must keep the incident command informed of.field monitoring teams ' activities and location. Coordination with.field monitoring teams and.field monitoring may be demonstrated as out-of-sequence demonstrations, as negotiated in the extent ofplay agreement.

Field measurements are needed to help characterize the release and support the adequacy of implemented protective actions, or to be a factor in modifying protective actions. Teams must be directed to take measurements at such locations and times as necessary to provide sufficient information to characterize the plume and its impacts.

Ifthe responsibility for obtaining peak measurements in the plume has been accepted by licensee Judd monitoring teams, with concurrence from OROs, there is no requirement/or these measurements to be repeated by OROs monitoring teams. Ifthe licensee field monitoring teams do not obtain peak measurements in the plume, it is the ORO 's decision as to whether peak measurements are necessary to sufficiently characterize the plume. The sharing and coordination ofplume measurement information among all.field monitoring teams (licensee, Federal, and ORO) is essential.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g. , compacts or the licensee) as necessmy. Evaluation ofthis criterion will take into considerarion the level ofFederal and other resources participating in the exercise.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

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PU ,GRIM NJJCIJ:AR POWER STATION EXERCISE- Noyemher 16. 2016 Massachusetts Extent of Play NIA T Field Teams aie managed by the Field Team Coordinator who are located at the utility EOF.

He/she will brief and in conjunction with the utility and other state agencies, dispatch two .teams to sampling locations in accordance with the NIAT Handbook, Section D.4, as dictated by scenario play. The NIAT Field Teams have been evaluated by FEMA during the Seabrook Exercise April 5, 2016. Both NIAT Field Teams will practice preparing one sample media and the report survey results on the appropriate survey forms to the Field Team Coordinator.

Criterion 4.a.3: Ambient radiation measurements are made and recorded at appropriate locations, and radioiodine and particulate samples are collected Teams will move to an appropriate low background location to determine whether any significant (as specified in the plan and/or procedures) amount ofradioactivity has been collected on the sampling media.

(NUREG.:()654/FEMA-REP-1, Cl; H.12; L 8, 9; J.10.a) '

Extent ofPlay Two or more field monitoring teams must demonstrate the capability to make and report measurements ambient radiation to the field team coordinator, dose assessment team, or other appropriate authority. Field monitoring teams must also demonstrate the capability to obtain an air sample for measurement ofairborne radioiodine and particulates, and to provide the appropriate authority with.field data pertaining to measurement. Ifsamples have radioactivity significantly above background, the authority must consider the needfor expedited laboratory analyses ofthese samples. Coordination concerning transfer ofsamples, including a chain-of-custodyform(s) , to a radiological laboratory{ies) must be demonstrated.

OROs must share data in a timely manner with all other appropriate OROs. All methodology, including contamination control, instrumentation, preparation ofsamples, and a chain-of-custody form(s)for transfer to a

/aboratory(ies), will be in accordance with the ORO 's plans/procedures.

OR Os will use Federa/ resources as identified in the NRF Nuclear/Radiological Incident A nnex and other resources (e.g., compacts or the licensee), as needed. Evaluation ofthis criterion will take into consideration the level ofFederal and other resources participating in the exercise.

All activities must be must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent of Play Two MA NIAT Field Teams will be dispatched from the EOF in accordance with theNIAT Handbook.

The NIAT Field Teams have been evaluated by FEMA during the Seabrook Exercise April 5, 2016. The NIAT Field Teams will be practicing during the Pilgrim Exercise. Once, dispatched, only disposable gloves will be used for actual exercise play. Charcoal cartridges will be used instead of silver zeolite.

Both NIAT F ield Teams will practice collecting one complete sample (monitoring and air sample) as specified by the procedure~ in Section D.4 of the NIAT Handbook.

Note: If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an "on the spot" training by the local or State representative, the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day.

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PU ,GBIM NITCJ,f:AB fOWEB STATTON FXEBCJSE - Noyember 16. 2016 Sub-element 4. b- Post Plume Phase Field Measurements and Sa fin Intent This sub-element is derivedfrom NUREG*0654/FEMA-REP-l , which requires thatOROs should have the capability to assess the actual or potential magnitude and locations ofradiological hazards in the ingestion exposure pathway EPZ and to support relocation, re-entry and re turn decisions. This sub-elementfocuses on the collecting environmental samplesfor laboratory analyses that are essentialfor decisions on protection ofthe publicfrom contaminatedfood and water and direct radiationfrom deposited materials.

Criterion 4. b. l: The field teams (2 or more) demonstrate the capability to make appropriate measurements and to collect appropriate samples (e.g.,jood crops, milk, water, vegetation, and soil) to support adequate assessments and protective action decision-making. (NUREG-0654/ FEMA-REP-l CJ; L8; J.11)

Extent ofPlay The ORO 'sjield monitoring teams must demonstrate the capability to take measurements and samples, at such limes and locations as directed to enable an adequate assessment ofthe ingestion exposure pathway and to support re-entry, relocation, and return decisions. When resources are available, use ofaerial surveys and in-situ gamma measurement is appropriate. All methodology, including contamination control, instrumentation, preparation ofsamples, and chain-of-custodyform(s)for transfer to a laboratory(ies), will be in accordance with the ORO 's plans/procedures.

The field monitoring teams and/or other sampling personnel must secure ingestion exposure pathway samplesfrom agricultural products and water. Samples in support ofrelocation and return must be securedfrom soil, vegetation, and other surfaces in areas that received radioactive ground deposition.

OROs will use Federal resources as identified in the NRF Nuclear/Radiological Incident Annex and other resources (e.g., compacts, the licensee, or nuclear insurers) as needed. Evaluation ofthis criterion will take into consideration the level ofFederal and other resources participating in the exercise.

All activities must be must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or othenvise specified in the extent ofplay agreement.

Massachusetts Extent ofPlay This sub-element will not be demonstrated during this exercise.

Level l or Level 2 Findings: NIA Note: If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an "on the spot" training by the local or State representative, the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day.

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pu ,GRIM NITCJ,EAR POWER STATTON f,XERCJSE - Noyember 16. 2016 ISub-element 4. c - laboratory Oeerations Intent This sub-element isderivedfromNUREG-0654/FEMA-REP-l , which requires thatOffsite Response Organizations (ORO) have the capability to perform laboratory analyses ofradioactivity in air, liquid, and environmental samples to support protective action decision-making.

Criterion 4. c. J: The laboratory is capable ofperforming required radiological analyses to support protective action decisions. (NUREG-0654/FEMA -REP-J, CJ, 3; J.11)

Extent ofPlay The laboratory staffmust demonstrate the capability to follow appropriate procedures for receiving samples, including logging ofinformation, preventing contamination ofthe laboratory(ies), preventing buildup of background radiation due to stored samples, preventing cross contamination ofsamples, preserving samples that may spoil (e.g. , milk), and keeping track ofsample identity. In addition, the laboratory staff must demonstrate the capability to prepare samplesfor conducting measurements.

The laboratory(ies) must be appropriately equipped to provide, upon request, timely analyses ofmedia of sufficient quality and sensitivity to support assessments and decisions as anticipated by the ORO 's plans/p rocedures. The laboratory instrument calibrations must be traceable to standards provided by the National Institute ofStandards and Technology. laboratory methods used to analyze typical radionuclides released in a reactor incident should be as described in the plans/procedures. New or revised methods may be used to analyze atypical radionuclide releases (e.g., transuranics or as a .result ofa terrorist event) or if warranted by incident circumstances. Analysis may require resources beyond those of the ORO.

The laboratory staffmust be qualified in radioanalytical techniques and contamination control procedures.

OROs will use Federal resources as identified in the NRF Nuclear/ Radiological Incident A nnex and other resources (e.g., compacts, the licensee, nuclear insurers) as needed. Evaluation of this criterion will take into consideration the level ofFederal and other resources participating in the exercise.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent ofPlay This sub-element will not demonstrated during this exercise Level 1 or Level 2 Findings: N/A Pilgiim £6P Ru . 8 Pagd6 of58 8~1!'1116

PU ,QRIM NJTCJ,EAR POWER STATION EX}i;RCJSE Ngyember 16. 2016 EVA L CIA TTON A BRA 5

• Rnzerggncy Nqtjficqtiqn qnd Public lnfnrmatian Sub-element 5.a-Activation ofthe Prompt Alert and Notification Svstem Intent This sub-element is derivedfrom NUREG-0654/FEMA -REP-l, which requires that 0 ROs have the capability to provide prompt instructions to lhe public within the plume palhway EP Z. Specific provisions addressed in this sub-e/emenl are farther discussed in Section V. Part A ofthe REP manual, Alert and Notification Systems.

Exhibil W -4: Evalualion Standards for Alert and Notificalion Svs1ems Demonstration JnaTunely W'uhin 45Minutes Within a CriJeria: Manner ReasonableTime Prin111T1J Alert andNotification 5.a.J: ... covering essentially 100% of x the I 0-mi/e EPZ 5.a.4: ...for FEMA-approved exception x areas Backup Alert andNotification for Alllncidents 5.a.3: ... covering the x 10-mileEPZ Criterion 5. a.I: Activities associated with p rimary alerting and notification ofthe public are completed in a timely manner following the initial decision by authorized offsite emergency officials to notify the public of an emergency situation. The initial instructional message to the public must include as a minimum the elements required by current REP guidance. (NUREG-0654/FEMA-REP-l, E.5, 6, 7)

Extetlt ofPlay Responsible Ojfsile Response Organizations (ORO) mus/ demonslrale the capability to sequentially provide an a/er/ signalfollowed by an initial ins/ructional message Jo populated areas (permanent residen/ and Jransienl) throughou/ the 10-mile plume pathway EPZ. Following Jhe decision Joactivale Jhe a/er/ and notification system, OR Os must complete system activationfar primary alert/notification and disseminate Jhe information/ins/ructions in a lime/y manner. For exercise pwposes, timely is de.fined as "with a sense of urgency andwithow undue delay. "Ifmessage dissemination is identified as not having been accomplished in a limely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Procedures to broadcast the message mus/ be folly demons/rated as they would in an actual emergency up to the point of1ransmission. Broadcast ofthe message(s) or test messages is not required. The procedures mus/ be demons/rated up to the point ofactual activation. The alert signal activation should be simulated, not performed. Evaluations ofEAS broadcast stations may also be accomplished through SA Vs.

The capability of/he primary notification system to broadcast an instructional message on a 24-hour basis must be verified during an interview with appropriate personnelfro m the primary notification system, including verification ofprovisions fo r backup power or an alternate station.

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PU,GBIM NI JQ,YAB fOWEB STATTON EXEBQSE- November 16. 2016 The initial message must include at a minimum the following elements:

Identification of the ORO responsible and the official with authorityfor providing the alert signal and instructional message; Identification ofthe commercial Nuclear Power Plant and a statement that an emergency exists there; Reference to REP-specific emergency information (e.g., brochures, calendars, and/or information in telephone books) for use by the general public during an emergency; and A closing statement asking that the affected and potentially affected populations stay tunedfor additional information, or that the population tune to another station for additiOna/ information.

Ifroute alerting is demonstrated as a primary method ofalert and notification, it must be done in accordance with the OROs plans/procedures and the extent ofplay agreement. OROs must demonstrate the capability to accomplish the primary route alerting in a timely manner (not subject to specific time requirements). At least one route needs to be demonstrated and evaluated. The selected route(s) must vary fro m exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (i.e. , the message that would actually be used is readfor the evaluator, but not actually broadcast) as negotiated in the extent ofplay. Actual testing ofthe mobile public address system wi/J be conducted at an agreed-upon location.

OROs must demonstrate any means ofprimary alert and notification included in their plans/procedures as negotiated in the extent ofplay agreement.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, except as noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent of Play The sounding of the sirens and broadcastofEAS/News Releases will be simulated. EAS/News Releases will be formulated and distributed by the Massachusetts State EOC. Actions to demonstrate performance of initial notification of the public will be performed up to the point ofactual transmission of the Emergency Alert System (EAS) message. The EAS message will be prepared/ encoded by MEMA. EAS radio station WBZ (1030 AM) will be initially contacted and faxed a copy of a standard test message.

Siren activation and broadcast ofEAS messages/News Releases will be simulated.

Level 1 or Level 2 Findings: NIA Criterion5.a.2: {RESERVED]

Criterion 5. a.3: Backup alert and notification ofthe public is completed within a reasonable time following the detection by the ORO ofa failure ofthe primary alert and notification system (NUREG0654/FEMA-REP-1, E. 6; Appendix 3.B.2.c)

Extent ofPlay Jftlze exercise scenario calls for failure ofany portion of the primary system(s) or if any portion ofthe primary system(s) actuallyfails to function during the exercise, OROs must demonstrate backup means of alert and notification. Backup.means ofalert and notification will differ from facility to facility.

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PU .GRIM NITQ .EAR POWER STATION EXERCISE- Noyember 16 2016 Backup alert and notificarion procedures that would be implemented in multiple stages mus/ be structured such that the population closest to the plant (e.g., wirhin 2 miles) is alerted and norifiedjirst.

The popularionsfarther away and downwind ofany poremial radiological release would be covered sequentially (e.g. , 2 10 5 miles.followed by downwind 5 to 10 miles, andfinally the remaining population as direcred by aurhoriries). Topography, population density, existing ORO resources, and timing will be considered in judging the acceptability of backup means ofalert and notification.

Although circumsrances may nor allow this fo r all siruations, FEMA and rhe NRC recommend rhar OROs and operators a/tempt to establish backup means thar will reach those in the plume exposure EPZ within a reasonable lime offa ilure of rhe primary alert and norification system, wirh a recommended goal of 45 minutes. The backup alert message muse, at a minimum, include: (1) a statement chat an emergency exists at the plant; and (2) instructions regarding where to obtain additional information.

When backup route alerting is demonstrated, only one route needs to be selected and demonstrated. A ll alert and notification activities along the route(s) must be simulated (i.e. , the message that would actually be used is readfor the evaluaror, but not acrually broadcast), as negotiated in the extent ofplay. Actual testing ofthe mobile public address system will be conducted at an agreed-upon location.

O ROs may demonstrate any means ofbackup alert and notification included in their p lans/procedures as negotiated in the Extent-of-Play Agreement.

A ll activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the Extent-of- Play Agreement.

Massachusetts Extent of Play This sub-element will not be demonstrated this iteration.

Level l or Level 2 Findings: N/A Criterion 5. a. 4: Activities assodatedwitli FEMA-approved exception areas (wliere applicable) are completedwitliin 45 minutesfollowing tlie initial decision by autliorized offsite emergency officials to notify tlie public of an emergency situation. (NUREG-0654/FEMA-REP-J, E. 6; Appendix3.B.2.c)

Extent ofPlay Offsite Response Organizations (ORO) with FEM4 -approvedexceptionareas (identified in the approved A lert and Notification System Design Report), 5to10 miles from the nuclear power plant, must demonstrate the capability to accomplish primary alerting and notification ofthe exceptionarea(s). FEMA and the NRC recommend thatOROs and operators establish means that will reach those in approvedexception areas within 45 minutes once the initial decision is made by authorized offsite emergency officials to notify the public ofan incident. The exception area alert message must, at a minimum, include (1) a statement that an emergency exists at the plant and (2) instructions regarding where to obtain additional information.

For exception area alerting, at least one route needs to be demonstrated and evaluated. The selected route (s) should vary from exercise to exercise. However, the most difficult route(s) must be demonstrated no less than once every 8 years. All alert and notification activities along the route(s) must be simulated (i.e., the message that would actually be used is readfor the evaluaror, but not actually broadcasted) as negotiated in the extent ofplay. Actual testing of the mobile public address system will be conducted at 8'Hl!'1116

PU ,GRIM NlfCJ,EAB POWER STATION EXEBQSE -Noyemher 16 2016 an agreed-upon location. For exception areas alerted by air/water craft, actual routes will be negotiated in the extent ofplay, but must be demonstrated no less than once every 8 years.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, except as noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent of Play This criterion is not required by the Massachusetts Radiological Emergency Response Plan.

Level 1 or Level 2 Findings: NIA rugnm tor Rev. o rage 40 ot so 0 11211 16

pU ,GRIM NI TCJ,EAR fOWER STATION EXERCISE- Noyember 16. 2016 Sub-element 5.b-Subse uent Emer en In ormation and Instructions or the Public andthe Media Intent This sub-element isderivedfrom NUREG-0654/FEMA-REP-l, which requires thatOffsite Response Organizations (ORO) have the capability to disseminate appropriate emergency information and instructions, including any recommended protective actions, to the public. In addition, NUREG-0654/FEMA -REP-I requires OROs to ensure that the capability exists for providing information to the media. This includes the availability ofa physical location for use by the media during an emergency.

NUREG-0654/FEA1A -REP-l also provides that a system should be available for dealing with rumors.

This system will hereafter be known as the '*public inquiry hotline. "

Criterion 5. b. l: OR Os provide accurate subsequent emergency information and instructions to the public and the news media in a timely nwnner. (NUREG-0654/FEMA -REP-1, E. 5, 7; G. 3. a, G.4. a, c)

Extent ofPlay The responsible ORO personnel/representatives must demonstrate actions to provide emergency information and instructions 10 the public and media in a timely manner following the initial alert and notification (not subject to specific time requirements). For exercise purposes, timely is defined as "with a sense ofurgency and without undue delay. " Ifmessage dissemination is identified as not having been accomplished in a timely manner, the evaluator(s) will document a specific delay or cause as to why a message was not considered timely.

Message elements: The ORO must ensure that emergency information and instructions are consistent with protective action decisions made by appropriate officials. The emergency information must contain all necessary and applicable instructions (e.g. , evacuation instructions, evacuation routes, reception center locations, what to take when evacuating, shelter-in-place instructions, information concerning protective actionsfo r schools and persons with disabilities and access/functional needs, and public inquiry hotline telephone number) to assist the public in carrying out protective action decisions provided. The ORO must also be prepared to disclose and explain the Emergency Classification level (ECL) of the incident. At a minimum, this information must be included in media briefings and/or media releases. OROs must demonstrate the capability to use language that is clear and understandable 10 the public within both the plume and ingestion exposure pathway EPZs. This includes demonstration ofthe capability to use familiar landmarks and boundaries 10 describe protective action areas.

The emergency information must be all-inclusive by including the four items specified under exercise Demonstration Criterion 5.a. land previously identified protective action areas that are still valid, as well as new areas. Information about any rerouting ofevacuation routes due to impediments should also be included. The OROs must demonstrate the capability to ensure that emergency information that is no longer valid is rescinded and not repeated by broadcast media. In addition, the OROs must demonstrate the capability to ensure that current emergency information is repeated at pre-established intervals in accordance with the plans/procedures.

OROs must demonstrate the capability to develop emergency information in a non-English language when required by the plans/procedures.

If ingestion pathway measures are exercised, OROs must demonstrate that a system exists for rapid dissemination ofingestion exposure pathway information to pre-determined individuals and businesses in accordance with the 0 RO 's plans/procedures.

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PU,GBJM NJTCJ ,EAB POWER STATTON f:XERCJSE- Noyember 16 2016 Media information: OROs must demonstrate the capability to provide timely, accurate, concise, and coordinated information to the news media/or subsequent dissemination to the public. This would include demonstration ofthe capability to conduct timely and pertinent media briefings and distribute media releases as the incident warrants. The OROs must demonstrate 1he capability to respond appropriately to inquiries from the news media. All information presented in media briefings and releases must be consistent with protective action decisions and other emergency information provided to the public. Copies ofpertinent emergency information (e.g., EAS messages and media releases) and media information kits must be available for dissemination to the media.

Public inquiry: OROs must demonstrate that an effective system is in place for dealing with calls received via the public inquiry hotline. Hotline staffmust demonstrate the capability to provide or obtain accurate information for callers or refer 1hem to an appropriate informalion source. Information from Ihe hotline staff. including information Iha/ corrects false or inaccurate information when trends are noted, must be included, as appropria/e, in emergency information provided to the public, media briefings, and/or media releases.

HAB considerations: The dissemination ofinformation dealing with specific aspecls ofNP P security capabili1ies, actual or perceived adversarial (1errorist)force or Ihreat, and Jactica/ law enforcement response must be coordina1edl communica1edwith appropriale security authorities, e.g .. law enforcement and NP P security agencies, in accordance with ORO plans/procedures.

All acJivities must be based on Ihe ORO 's plans/procedures and comple1ed, as /hey would be in an actual emergency, unless noted above or 01herwise specified in the extent ofplay agreement.

Massachusetts Extent ofPlay Joint Information Center: Information generated as a result of incoming calls to the SEOC Public Information Line/MASS 211 Call Center will be included in news briefings. At least two rumor trends will be handled.

State EOC: Control cell personnel will make calls simulating members of the public. The MASS 2!!

Call Center will demonstrate the ability to handle public inquiry calls. Handling at least two rumor trends (three or more calls of the same nature) will be demonstrated. Two MASS 211 public information line operators each will respond to calls once the Public Alert and Notification System has been activated at Site Area Emergency or General Emergency at the State EOC.

Each local EOC w ill demonstrate the community's emergency response and refer all other questions to MASS 211 Call Center.

Level I or Level 2 Findings: N/A Note : If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an " on the spot" training by the local or State representative, the FEMAEvaluatorwill provide another opportunity to re-demonstrate the activity that day.

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PU ,GBIM Nl!CJ.EAB POWER STATION f:XEBCISE-Noyemher 16. 2016 t:VALCIAUoNAREA 6* Sunnqrt Opgrqtiqnffqdlitigs Sub-element6.a-Monitoring. Decontamination and Registration o(Evacuees Intent Thissub-elementisderivedfromNUREG-0654/FEMA-REP-l , whichrequiresthatOffsite Response Organizations (ORO) have the capability to implement radiological monitoring and decontamination of evacuees, while minimizing contamination ofthe facility. OROs must also have rhe capability to identify and regisrer evacuees at reception centers.

Criterion 6.a.J: The reception centerfacility has appropriate space, adequate resources, and trained personnel to provide monitoring, decontamination, and registration ofevacuees.

(NUREG-0654/FEMA-REP-1, A.3; C4; J.10.h; J.12)

Extent ofPlay Radiological monitoring, deconramination, and regisrrationf acilitiesfor evacuees must be ser up and demonstrated as they would be in an actual emergency or as indicated in the extent ofplay agreement.

OROs conducring this demonstration must have 113 ofthe resources (e.g. , monitoring teams/ instrumentarionlportal monitors) available at the f acility(ies) as necessary to monitor 20% ofthe population within a 12-hour period. This would include adequate space for evacuees ' vehicles.

Availability of resources can be demonstrated with valid documentation (e.g. , MOU/LOA, etc.) reflecting how necessary equipment would be procured fo r the location. Plans/procedures must indicate provisions for service animals.

Before using monitoring instrument(s) , the monitor(s) must demonstrate the process ofchecking the instrument(s) for proper operation. Staffresponsible for the radiological monitoring ofevacuees must demonstrate the capability to a/lain and sustain, within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, a monitoring productivity rate per hour needed to monitor the 20% emergency planning zone (EPZ) population planning base. The monitoring producrivity rare per hour is rhe number ofevacuees thar can be monitored, per hour, by rhe rota/ complement ofmonitors using an appropriare procedure. For demonstration ofmonitoring, decontamination, and registration capabilities, a minimum ofsix individuals per monitoring station must be monitored per station using equipment and procedures specified in rhe plans/procedures. The monitoring sequences for thefirsr six simulated evacuees per monitoring team will be timed by the evaluarors in order to determine whether the twe lve-hour requirement can be me t.

OROs must demonstration the capability to register evacuees upon completion ofthe monitoring and decontamination activities. The activities for recording radiological monitoring and, ifnecessary, decontamination must include establishing a registration record consisting ofthe evacuee 's name, address, results ofmonitoring, and time ofdecontamination (ifany), or as othen11ise designated in the plan and/or procedures. Audio recorders, camcorders or written records are all acceptable means fo r registration.

Monitoring activities shall nor be simulated. Monitoringpersonnelmustexplain use oftrigger/action levels for determining the needfor decontamination. They must also explain the procedures for referring any evacuees who cannot be adequately decontaminatedfor assessment andfo llow-up in accordance with the ORO 's plans/procedures. All activities must be based on the ORO 's plans/p rocedures and completed as they would be in an actual emergency, unless noted above or othen11ise specified in the extent ofplay agreement.

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PU ,GRIM NI!CJ,EAR POWER STATTON EXERCISE- Noyemher 16 20J6 Decontamination ofevacuees may be simulated and conducted by interview. Provisionsfor separate showering and same-sex decontamination must be demonstrated or explained The staffmust demonstrate provisionsfor limiting the spread ofcontamination. Provisions could include floor coverings, signs, and appropriate means (e.g. , partitions, roped-offareas) to separate uncontaminatedfrom potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated evacuees, provide changes ofclothing/or those with contaminated clothing; and store contaminated clothing and personal belongings to preventfarther contamination ofevacuees orfacilities. In addition.for any evacuee found to be contaminated, procedures must be discussed concerning the handling ofpotential contamination ofvehicles and personal belongings. Waste water from decontamination operations does not need to be collected.

Individuals who have completed monitoring anddecontamination, ifneeded must have means (e.g. , hand stamp, sticker, bracelet,form, etc.) indicating that they, and their service animals and vehicles, where applicable, have been monitored, cleared, andfound to have no contamination or contamination below the trigger/action level or have been placed in a secure area until they can be monitored and decontaminated, if necessary.

In accordance with plans/procedures, individualsfound to be clean after monitoring do not need to have their vehicle monitored These individuals do not require confirmation that their vehicle isfree from contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminatedwill have their vehicles held in a secure area or monitored and decontaminated (ifapplicable) and do require confirmation that their vehicle is being held in a secure area orfree from contamination prior to entering the congregate care areas.

Massachusetts Extent of Play This sub-element will not be demonstrated during this exercise.

Level l or Level 2 Findings: NIA Note: If, during the exercise, a participant demonstrates this sub-element unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an "on the spot" training by the local or State representative, the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day.

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PU .GR IM NJ JCJ ,EA R POWER ST ATION EXEBQSE - Noyember 16 2016 and Decontamination o Emer<>en Workers an d their E ui ment and Intent This sub-elemenl is derivedfrom NUREG-0654/FEMA-REP-I, which requires that Offs ire Response Organizations (ORO) have the capability to implement radiological monitoringanddeconlamination of emergencyworkers and their equipment, inclusive ofvehicles.

Criterion 6. b. l : T/1 e facility/ORO has adequate procedures and resources to accomplish monitoring and decontamination of emergen cy workers an d their equipment and vehicles.

(NUREG-0654/FEMA -REP -l,K. 5. a, b)

Extent of Play The monitoring staffmust demonstrate the capability lo monitor emergency worker personnel and Jheir equipment andvehiclesfor conlamination in accordance with the Offsite Response Organizations (ORO) plans/procedures.

Specific a/lention must be given to equipment, including any vehicles that were in contact with contamination. The monitoring staffmust demonstrate the capability to make decisions on the needfor decontamination ofpersonnel, equipment, and vehicles based on trigger/action levels and procedures stated in the OROs plans/procedures. Monitoring ofemergency worker> does not have to meet the 12-hour requirement. However, appropriate monitoring procedures must be demonstratedfor a minimum of 2 emergency workers and their equipment and vehicles. Before using monitoring instrument(s), the monitor(s) must demonstrate the process ofchecking the instrumenl(s)for proper operation.

The area to be usedfor monitoring and deconlaminalion must be set up as it would be in an aclual emergency, with all route markings, instrumenlalion, record keeping and contamination control measures in place. Monitoring procedures must be demonstrated for a minimum of one vehicle. It is generally not necessary to monitor the entire surface ofvehicles. However, the capability to monitor areas such as radiator grills, bumpers, wheel wells, I ires, and door handles must be demonstrated. Interior surfaces of vehicles thal were in contaclwilh con1amina1ed individuals must also* be checked.

Decontaminalion ofemergency workers may be simulated and conducted via interview. Provisions for separate showering and same-sex decontamination must be demonstrated or explained. The staffmust demonstrate provisions for limiting the spread ofcontamination. Provisions could include floor coverings, signs and appropriate means (e.g. , partitions, roped-offareas) to separate uncontaminated from potentially contaminated areas. Provisions must also exist to separate contaminated and uncontaminated individuals where applicable, provide changes ofclothing/or those with contaminated clothing and slore contaminated clo1hing and personal belongings to prevent.further contaminalion of emergencyworkers orfacilities.

OROs must demonstrate the capability to regisler emergencyworkersupon completion ofthe monitoring and decontamination activities. The activiliesfor recording radiological moniloring and ifnecessG!y, decontamination must include establishing a registration recordconsisting ofthe emergency worker 's name, address, results ofmonitoring, and time ofdecontamination (ifany), or as otherwise designated in the plans/

procedures. Audio recorders, camcorders, orwritlen records are all acceptable meansfor registration.

Monitoringaclivities shall not be simulated. Monitoring personnel must explain use oftrigger/action levels for determining the needfor decontamination. They musl also explain the proceduresfor referring any Pilgrim EOP Rev. 0 Page 45 of 50 07/27/16

PU ,GBIM NlICiiEAB POWER STATTON EXEBQSE - Noyemher 16. 2016 emergencyworkerswho cannot be adequately decontaminatedfo r assessment andfollow -up in accordance with the ORO 'splans/procedures.

Decontamination capabilities and provisions for vehicles and equipment that cannot be succesifully decontaminated may be simulated and conducted by interview. Waste water from decontamination operations does not need to be collected All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent ofPlay This sub-element will not be demonstrated during this exercise.

Level I or Level 2 Findings: NIA Note: If, during the exercise, a participant demonstrates this sub-eleme nt unsatisfactorily, the FEMA Evaluator will inform the MEMA Controller. After an "on the spot" training by the local or State representative, the FEMA Evaluator will provide another opportunity to re-demonstrate the activity that day.

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PU ,GB!M NJTQ,EAB POWER STATION EXEBCJSE- Noyember 16 2016 ISub-element 6. c- Temporary Care o(Evacuees Intent This sub-element is derivedfrom NUREG-0654/FEMA-REP-l , which requires 1hat Offsile Response Organiza/ions (ORO) to have the capability toe stablish relocation centers in host/supportjurisdictions. The American Red Cross normally provides congregate care in supporl ofOROs under existing letters of agreement.

Criterion 6.c.1: Managers of congregate care facilities demonstraJe thaJ the centers have resources to provide services and accommodations consistent with American Red Cross planning guidelines. Managers demonstrate the procedures to assure thaJ evacuees have been monitoredfor contamination and have been decontaminaJed as appropriate prior to entering congregaJecarefacilities. (NUREG-0654/FEMA-REP-1, J.10.h, J.12)

Extent ofPlay The evaluator must conduct a walk-through ofthe center to determine, through observation and inquiries,

• that the services and accommoda1ions are consistentwith applicable guidance.

For planning purposes, OROs mus/ plan fora sufficient number ofcongregate care centers in host/support jurisdictions based on their a//-hazardshelteringexperience and what is historically relevantfor that particular area. In this simulation, it is not necessary to set up operations as they would be in an actual emergency. Alterna1ively, capabilities may be demonstrated by setting up stationsfor various services and providing those services to simulated evacuees. Given 1he substantial differences be/Ween demonstration and simulation ofthis criterion, exercise demonstration expectations must be clearly specified in extent-of-play agreements.

Congregate care s1affmus/ also demonstrate lhe capability to ensure that evacuees, service animals, and vehicles have been monitoredfor contamination, decontaminated as appropriale, and registered before entering thefacility.

Individuals arriving at congregate carefacilities must have means (e.g. , hand stamp, sticker, bracelet.form, etc.) indicating that they, and their service animal and vehicles, where applicable, have been placed in a secured area or monitored, cleared, andfound to have no contamination or contamination below the trigger/action/eve/.

Jn accordance with plans/procedures, individualsfound to be clean after monitoring do not need to have their vehicle monitored These individuals do not need corifirmation 1hat their vehicle isfree from contamination prior to entering the congregate care areas.

However, those individuals who are found to be contaminated and are then decontaminated will have 1heir vehicles held in a secure area until 1hey can be monitored or decontaminated (ifapplicable) and do need corifirmation 1hat their vehicle is being held in a secure area or free from contamination prior to entering the congregate care areas. This capability may be determined through an interview process.

Ifoperations at the center are demonstrated, material that would be difficult or expensive to transport (e.g. ,

cots, blankets, sundries, and large-scalefood supplies) need not be physically available at thefacility(ies).

However, availability ofsuch items must be verified by providing the evaluator a /isl ofsources with locations and eslimates ofquantities.

Pilgrim EOP Rev. 0 Page 47 of 50 07127/16

PU ,GBIM NJJCJ ,EAB POWE R STATION EXEBCJSE - Npyemher 16. 2016 All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent of Play This sub-element will not be demonstrated during this exercise.

Levell or Level 2 Findings: N/A Htgnm EOP Kev. 0 rage 48 at so Off Zfl i6

PU ,GRJM NJJCU;AB POWER STATTON EXERCJSE - Ngyemher 16 2016 Sub-e/ement6. d - Trans ortation and Treatment o Contaminated In 'ured Individuals Intent This sub-element is derivedfrom NUREG-0654/FEMA-REP-l , which requires thatOffsile Response Organizations (ORO) have the capability to transport contaminated injured individuals to medica/facilities with the capability to provide medical services.

Criterion 6. d I: The facility/ORO has the appropriate space, adequate resources, and trained p ersonnel to provide transport, nwnitoring, decontamination, and medical services to contaminatedinjured individuals. (NUREG-0654/FEMA -REP-I, F.2; H.I O; K. 5.a, b; LI, 4)

Extent of Play Monitoring, decontamination, and contamination control efforts must not delay urgent medical care for the victim.

Offsite Response Organizations (ORO) must demonstrate the capability to monitor/decontaminate and transport contaminated, injured individuals to medicalfacilities.

An ambulance must be usedfor the response to the victim. However, to avoid taking an ambulance out of service for an extended time, OROs may use any vehicle (e.g., car, truck, or van) to transport the victim to the medical facility. It is allowable fo r an ambulance to demonstrate up to the point ofdeparture for the medical facility and then have a non-specialized vehicle transport the "victim(s) " to the medical facility.

This option is used in areas where removing an ambulance from service to drive a great distance (over an hour) for a drill would not be in the best interests ofthe community.

Normal communications between the ambulance/dispatcher and the receiving medicalfacility must be demonstrated. Jfa substitute vehicle is usedfor transport to the medicalfacility, this communication must occur before releasing the ambulance from the drill. This communication would include reporting radiation monitoring results, ifavailable. Jn addition, the ambulance crew must demonstrate, by interview, knowledge ofwhere the ambulance and crew would be monitored and decontaminated, if required, or whom to contactfor such information.

Monitoring ofthe victim may be performed before transport or enroute, or may be deferred to the medicalfacility. Contaminated inj ured individuals transported to medicalfacilities are monitored as soon as possible to assure that everyone (ambulance and medica!jacility) is aware ofthe medical and radiological status ofthe indtvidual(s). However, ifan ambulance defers monitoring to the medical facility, then the ambulance crew presumes that the patient(s) is contaminated and demonstrate appropriate contamination controls until the patient(s) is monitored. Before using monitoring instruments, the monitor(s) must demonstrate the p rocess ofchecking the instrument(s)for proper operation. All monitoring activities must be completed as they would be in an actual emergency.

Appropriate contamination control measures mus.I be demonstrated before and during transport and at the receiving medicalfacility.

The medical facility must demonstrate the capability to activate and set up a radiological emergency area for treatment. Medical facilities are expected to have at least one trained physician and one trained nurse to perform and supervise treatment ofcontaminated injured individuals. Equipment and supplies must be available for the treatment ofcontaminated injured individuals.

Pilgrim EOP Rev. 0 Page 49 of 5-0 07127116

PILGRIM Nl lCJ,EAR POWER ST ATION f:XERCJSE Noyember 16. 2016 The medicalfacility must demonstrate the capability to make decisions on the needfor decontamination of the individual.follow appropriate decontamination procedures, and maintain records ofall survey measurements and samples taken. A ll procedures for the collection and analysis ofsamples and decontamination ofthe individual must be demonstrated or described to the evaluator. Waste water from decontamination operations must be handled according to facility plans/procedures.

All activities must be based on the ORO 's plans/procedures and completed as they would be in an actual emergency, unless noted above or otherwise specified in the extent ofplay agreement.

Massachusetts Extent of Play Good Samaritan Hospital will be demonstrated out of sequence September 2016 Level l or Level 2 Findings: NIA Pilgrim EOF ReV. 0 rage so 01 so 0 112111 6

Unclassified Radiological Emergency Preparedness Program (REP)

After Action Report/lmprovement Plan Pilgrim Nuclear Power Station Appendix D: Pilerim Exerdse Scenario Summary*

Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise SCHEDULE OF EVENTS*

34

SCHEDULE OF ACTIVITIES pre-Exercjse Event: TSC/OSC Player Briefing*

Date: Monday, November 7 2016 Time: 1000-1130 .

Location: TSC/OSC Attendees: TSC/OSC Players Event: EOE Player Brjefing*

Date: Monday, November 7, 2016 Time: 1400-1530 Location: EOF Attendees: EOF Players Event:

• JIC Player Briefing*

Date: Tuesday, November 8, 2016 Time: 0730-0900 Location: Industrial Park - Classroom 4 Attendees: JIC Players Event:.

• Controller Briefing Date: Wednesday, November 9, 2016 Time: 1300 - 1500

• Location: ESB Conference Room 2A/B Attendees: All Controllers Event: NBC Entrance Date: Monday November 14, 2016 Time: 1300 Location: TBD Attendees: Lead Facility Controllers, Leadership Team Event: EEMA Evaluator Briefing Date: Tuesday, November 15, 2016 Time: 1000 Location: Hampton Inn, Plymouth Attendees: selected individuals for scenario review

Exercise Event: NRC/FEMA Evaluated Exercise ..

Date: Wednesday, November 16, 2016

. Time: 0800 to Drill Termination Location: Simulator, TSC, OSC, EOF, JIC Attendees: All Players and All Controllers Post-Exercjse Event: Lead Controller Debrjef Date:' Wednesday, November 16, 2016 Time: 1600 - 1800 Location: CR 2A/B Attendees: Drill Coordinator, Lead Facility Controllers and Players and EP Event: Exercise Results - Persentation to Management Team/NBC*

Date: Thursday, November 17, 2016

• Time: 1600 - 1700 (tentative)

Location: CR3A Attendees: Senior Team, Lead Facility Controllers and Lead Drill Players, EP Event: NRC Exjt*

Date: Friday,November18,2016 Time: 0830 (tentative)

Location: CR3A Attendees: Senior Team, Lead Facility Controllers and Lead Drill Players, EP Event: EEMA Public meeting*

Date: Friday,November18,2016 Time: 1100 Location:. Hampton lrin, Plymouth Attendees: EP, RAPID.members pf Senior Team,

• *Presentation to Management and NRC Exit are dependent on drill and inspection results

Pilgrim Nuclear Power Station November 16, 201616-04 NRC/FEMA Evaluated Exercise

• PartiCipating Agencies:

Commonwealth of Massachusetts .

• Massachusetts Emergency Management Agency (MEMA)

Massachusetts Department of Public Health (MDPH)

EPZ Communities Town of Plymouth Town of Carver Town of Kingston Town of Duxbury Town of Marshfield Reception Communities

• Taunton

, Bridgewater Braintree

Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise Plant and Player Safety Considerations:

• Do NOT operate any plant equipment

• Personnel are required to maintain safe operation (i.e., on-shift operators) of the plant will be exempt from drill activities. Do not interact with the on-sh ift operating crew

• Never violate Industrial Safety, Radiation Protections, Operations or Security procedures/regulations

• Drill communications over radios and telephones are to be prefaced and followed by "THIS IS A DRILL." Face-to-face communications do not require this statement

• Use 3 part communication especially with numbers, units of measure, etc.

• If a plant issue/actual emergency arises you will be informed by the facility controllers to suspend the drill. *

• Participants must respond to simulated events as if they are real. This includes but is not limited to the following: [As amended by extent of play or controllers]

(a) Wearing of dosimetry and protective clothing.

(b) Obs~rving good radiation protection practices (c) Minimizing exposures (d) Responding to failed instruments in the field (e) Reporting hazards to the correct personnel (f) Proper contamination control

• All normal site procedures and rules are to be followed when entering the protected area and actual radiological controlled or radiation areas. NO ONE, including controllers, and observers, are exempt from normal station radiological or safety practices

• Read/review your procedures/position books. A drill is an infrequently performed task.

---~-~.

Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES

Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES .

A.1 Command and Control Demonstrate the ability of the Emergency Director or Facility Lead/Manager to provide overall direction (command and control) by initiating, coordinating and implementing timely and effective actions during the event. .

Demonstrate the ability of the Emergency Director to provide overall direction (command and control) by initiating, coordinating and implementing timely and effective actions during the event.

A.2 .Operatjonal Agreements Demonstrate the coordination of the implementation of emergency mea~ures and the exchange of information between the utility and Federal, State and local agencies and other support organizations having an emergency response role within the EPZ.

A.3 Contjnyous Operatjons Demonstrate the capability to establish and maintain continuous (24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) operations for a protracted period.

• B.1 Shjft Staff Response Demonstrate the ability of the normal staff complement to perform the functions of the on-shift ERO.

B.2 On-shjft Emergency Djrectjon Demonstrate the Shift Manager's ability to immediately and unilaterally initiate any emergency response action, including providing protective action recommendations to authorities responsible for implementing offsite emergency measures.

B.3 Line of Syccessjon Demonstrate the ability to transfer overall command and control of the emergency response.

B.4 Non-Pelegable Responsjbi!itjes Demonstrate the performance of authority of the non-delegable responsibilities.

B.5 Mjnjmym ERO Staffjng Demonstrate the ability to augment the on-shift response capabilities within a short period of time.

B.6 Fyl! ERO Staffjng Aygmentatjon Demonstrate the ability of management, administrative and technical support personnel to augment the plant staff in the areas of logistics support, technical support, government interface, and public information.

B.7 ERO Sypportbraanjzatjons.

Demonstrate the ability of specified contractor and private support organizations to provide technical assistance.to or augmentthe ERO.

B.10 24 Hoyr per day Emeraency Response Capabilitjes Demonstrate planning for 24-hour per day emergency response capabilities.

C.2 Commynjty Representatjye Demonstrate the ability to provide a liaison at each participating offsite governmental Emergency Operations Center (EOC).

D.1 Classificatjon

• Demonstrate the ability to recogniz!= the initiating conditions for EALs and to properly classify emergencies.

E.1 Off-sjte Notificatjon Demonstrate the ability to notify the offsite Emergency Response Organizations (ORO) consistent with the classification scheme including the verification of messages in a timely manner.

. Pilgrim Nuclear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES (cont)

E.2 ERO Notificatjon Demonstrate the ability to alert, notify and mobilize ERO personnel.

E.3 lnjtjal Notificatjon Message Content Demonstrate the ability to provide the required content for the initial notification messages accurately within the required time limit.

E.4 Eollow*yp Message Content Demonstrate the ability to provide the required content for the follow-up notification messages timely and accurately.

F.1 State/Local Commynjcajjons System Demonstrate the ability to operate the communications systems used by the ERO to provide information to the State and local agencies.

E.2 Federal Commynjcatjons System Demonstrate the ability to operate the communications systems used by the ERO to provide information to federal agency(s). ,"

F.3 Emeraency Response pata System lERDSl

• Demonstrate the ability to activate EROS as soon as possible but no later than one hour after declaration of an emergency of an Alert or higher emergency classification.

F.4 Utility Commynjcatjons System Demonstrate the ability to operate the communications systems used by the ERO to exchange information with other emergency response facilities.

G.1 JIC Sypport of Emeraency Demonstrate the adequacy of the JIC to. support emergency response activities.

G.2 Medja Brjefinqs-Demonstrate the ability of the Spokesperson to brief the media in a clear, accurate and timely manner.

G.3 Exchange of Public lntormatjon Demonstrate the timely exchange of public information among designated agency spokespersons.

• G.4 pyblic lngyjrv <Rymor Control)

Demonstrate the ability to establish and operate an effective system for dealing with calls to the public inquiry hotline.

• G.5 Release of lntocmatjon Demonstrate the ability to develop and release information to the media/public for a declared emergency.

H.1 !SC Sypport of Emeraency Operatjons Demonstrate the adequacy of the TSC to support emergency response activities.

H.2 EOE Sypport of Emergency Operatjons Demonstrate the adequacy of the EOF to support emergency response activities:

H.3 OSC Sypport of Emeraency Operatjons Demonstrate the adequacy of the OSC to support emergency response activities.

H.4 Tjmely Facility Actjyatjon Demonstrate the ability to activate the emergency response facilities in a timely manner.

H.10 Control Room pjrectjon and Control Demonstrate effective direction and control for onsite resources to support assessment and mitigation of the event.

Pilgrim Nuclear Power Station

• November 16, 201616-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES <cont)

H.11 !SC Pirection and Control Demonstrate effective direction and control for facility resources to support assessment and mitigation of the event.

H.1ZEOE pjrectjon and Control Demonstrate effective direction and control for facility resources to support facility priorities.

H.14 EOE pjsplay Capabjljtjes Demonstrate the capability for obtaining and displaying plant data and radiological information for each reactor at the station and each station supported by the facility.

H.15 EOE Technical Capabi!itjes Demonstrate the capability to analyze plart technical information and provide technical briefings on event prognosis to station and off-site response organizations for each reactor at the station and each station supported by the facility.

H.17 Meterologjcal Pata Demonstrate the ability tci obtain current and forecasted meteorological information from primary as well.as backup and alternate sources.

1.1 Accjdent Recognjtjon and Assessment Demonstrate the ability to provide initial values and continuing assessment throughout the course of an accident as well as the parameter values that correspond to the initiating conditions for EALs and PARs.

1.2 Core carnage Assessment Demonstrate the ability to determine the extent of core failure based on station-specific assessment strategies and sampling, 1.3 Release and Pose Assessment Demonstrate the ability to determine the magnitude of radioactive releases or perform dose assessments based on plant parameters, effluent monitors, field data and meteorological conditions.

1.5 Health physjcs - In Plant Monjtorjnq Demonstrate response and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment..

1.6 Health Physjcs - Enyjronmental Release Monjtorjng Demonstrate response and analysis of simulated elevated airborne and liquid samples and direct radiation measurements in the environment.

1.7 OM! Support of Emeraency OperatjOns .

Demonstrate the adequacy of the OMTs to support emergency response activities.

1.8 Plyme phase Monjtorjnq Demonstrate the ability to monitor radiological releases to the environment in the field.

J.1 Warnjng On-Sjte personnel Demonstrate the means to alert individuals at the site and persons who may be in the public access areas within the owner controlled area.

J.4 Assembly and Accoyntability Demonstrate the ability to perform accountability for all individuals in the Protected Area within 30 minutes o~,declaration.

., ~*

-~-- -. -- -*- ---

Pilgrim Nuc.lear Power Station November 16, 2016 16-04 NRC/FEMA Evaluated Exercise EXERCISE OBJECTIVES (cont>

J.5 Personnel protectjon Equioment Demonstrate the availability and use of respiratory protections and protective clothing for onsite emergency response personnel.

J.6 potassjym lodjde tK1l Demonstrate the availability and use* of potassium iodide (Kl) for utility emergency response personnel.

• J. 7 Protective Action Recommendations (.PABl.

• Demonstrate the ability to recommend protective actions to appropriate offsite authorities.

K.2 Exposyre Monjtorjnq Demonstrate the ability to control and track emergency 'worker radiation exposure.

K.3 personnel Qecontaminitjon Controls Demonstrate the use of action levels for determining the need for decontamination, perform decontamination and provide for waste disposal.

K.4 Area Contamjnatjon Controls

• Demonstrate contamination control practices.

K.5 Habjtability Controls Demonstrate the capability to minimize ERO internal contamination through ERF habitability controls and controlling the intake of drinking water and food supplies.

N.1 Exercjse and prms .

Demonstrate the ability to conduct drills and exercises which evaluate *key skills, overall emergency response capabilities and formal critiques identifying weaknesses or deficiencies requiring action.

N.2 Plans. procedyres. Facilitjes and .Eqyjpment Personnel, plans, procedures, facilities and equipment are tested and maintained ready to respond to emergencies, from minor events to severe acddents.

Pilgrim Nuclear Power Station November 16111 2016 NRC/FEMA Evaluated Exercise Scenario Timeline and Messages. /-

Page 1-1 Updated 9/13/16 08:00 hrs

Pilgrim Nuclear Power Station _

111 November 16 2016 NRC/FEMA Evaluated Exercise 1 Narrative Initial Conditions It is November 16th, 2016. At the start of the exercise, the plant is at 100% power and has been on line for 63 days.

A nor'easter impacted the site yesterday. Local communities have experienced some beach erosion however all major roads are passible and impact from the storm has been minimal.

The site is continuing to experience astronomically high tides from the storm and the full moon. High tide is expected around 1000 hrs. The wind is from the North East at 8-10 mph at 45°. Travelling screens are running fast and being monitored locally. It is a cloudy day with temperatures in the 50's F. The weather forecast predicts the winds to remain relatively constant from the North East at 8-10 mph. Skies are expected to remain cloudy throughout the day.

Sequence of Eyents (0805) The Exercise is initiated when Control Rod 26-27 drifts out. The operators are expected to respond to the rod drift per ARP-C905L & PNPS 2.4.11 and return 26-27 to its required position. However the rod will continue to drift out, forcing the operators to insert the rod to 00 and disable it. This rod drift will be the start of some minor (<3%)

fuel clad failure (not visible to crew at this time). PNPS procedure 2.4.40, "Rapid Increase in Main Steam Line or Offgas Activity" requires a reactor coolant sample be analyzed for evidence of fuel failure.

(0820) Crew recognizes increased sea water level. Crew recognizes sea water bay level has exceeded 13' 6". Shift Manager will declare an UNUSUAL EVENT based on EAL HU1.5:

• Sea water bay water level> +13' 6" MSL (Ll-3831A/B)

OR Sea water bay water level < -13' 9" MSL (Ll-3831 A/B)

Operations reports that sea water bay level is upscale high and requests field operator to report local sea water level readings. An operator is dispatched per 5.3.8, Att 2 or 3.

Main Steam and Off-gas radiation levels are trending upward due to minor fuel cladding failure resulting from the rod drift. Emergency Plant Information Computer (EPIC) alarms are received.

(0850) Field operator reports that sea water intake levels are +16'4" and continuing to rise slowly. Crew recognizes rising sea level and Shift Manager declares an ALERT based on EAL HA 1.6

• Sea water bay water level > +16' O" MSL OR Sea water bay water level < -16' O" MSL Page 1-2 Updated 9/13/16 08:00 hrs

Pilgrim Nuclea.r Power Station November 16th 2016 NRC/FEMA Evaluated Exercise When the Alert is declared, the emergency response organization (ERO) is notified by activation of the Emergency Response Organization Notification system. When sufficient numbers of the ERO arrive at the Technical Support Center (TSC), the Operations Support Center (OSC), the Emergency Operations Facility (EOF), and the Joint Information Genter (JIC), each facility will become operational.

Shortly following the Alert, EOG "A" trouble alarm comes in due to low start air pressure. NLO will be sent to investigate cause. A review of the Annunciator Response Procedure (ARP) indicates the air pressure is below the set point for the valve. The valve Is lifting and is not reseating.

After the ALERT and when all facilities are declared operational, the Main Steam Line (MSL) B Flow Indicator, Fl-640-23B, fails downscale resulting in a small transient observed by the Control Room Operators which results in slightly lower reactor vessel level. Feedwater level control is affected and crew may take manual control of feed -

regulating valves. Operations should ask for a team to troubleshoot and repair the indicator.*

Approximately one hour and fifteen minutes after the ALERT has been declared, a leak develops on the Reactor Water Clean Up (RWCU) at E-208C head, discharging primary coolant i,nto the Reactor Building (-20 gpm) which will not isolate (Supply valves M0-1201-02 and M0-1201-05 will not close). Secondary Containment temperature and radiation levels increase to Max Normal values. Operators enter EOP-04 based on the rising Secondary Containment temperatures. The reactor is scrammed per EOP-04 when max normal values are reached with primary system discharging into secondary containment. Operators should determine that a leak has occurred in the RWCU HX Room and RWCU failed to isolate. Attempts to isolate M0-1201-02 and M0-1201-05 from the simulator control room are unsuccessful.

Conditions are met for a SAE based on EAL FS1 .1 "Loss of any two barriers" Criteria C.9 or C.14 and C.18. The Emergency Director in the EOF should make the determination that an unisolable primary system is discharging outside primary containment. This requires an upgrade to SITE AREA EMERGENCY based on EAL FS1 .1 "Loss or Potential Loss of two Fission Product Barriers".

• *The two fission product barriers are Loss of RCS (criterion 9) or Potential Loss of RCS (criteria 14) and Loss of Primary Containment Barrier (criterion 18).

The transient from the reactor scram causes additional fuel to fail. Fission products have entered into the Reactor Coolant system and also into the Reactor Building via

• the RWCU system leak from which they are collected by the Standby Gas Treatment System and flow through the Main Stack for monitoring and discharge.

Main Steam and Off-gas radiation levels are trending upward due to fuel failure from the rod drift ana the scram transient. PNPS procedure 2.4.40, "Rapid Increase in Main Steam Line or Offgas Activity. directs Main Steam Isolation Valve (MSIV) closure upon reaching Main Steam Line Radiation High-High set point. Crew may isolate MSIVs before reaching set point. The MSIV closure will force more fission products to escape via the RWCU leak. Chemistry personnel should be directed to obtain a reactor

• coolant sample. Operations would be expected to aggressively pursue cool down and Page 1-3 Updated 9/13/16 08:00 hrs

Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise reducing reactor vessel pressure per EOP-04 in order to minimize or stop the leak.

The opening of the SRVs to maintain reactor pressure will also raise the activity in containment.

• About one hour after Site Area Emergency, a Torus High Range Monitor exceeds SOR/hr. Staff should recognize this as an indication of failed fuel clad barrier and combined with the SAE conditions, this meets GE criteria. The Emergency Director in the EOF is expected to upgrade the event to a GENERAL EMERGENCY (GE) based on EAL FG1 .1: Loss of two barriers and loss or potential loss of third barrier.

• The three fission product barriers are Loss of Fuel Clad (criteria 2), Loss of RCS (criterion 9) or Potential Loss of RCS (criteria 14) and Loss of Primary*

Containment Barrier (criterion 18).

At the time of declaring the General Emergency, the ERO will formulate and issue Protective Action Recommendations.(PAR) with the initial General Emergency declaration. The PAR should include evacuating the 2 mile ring surrounding the plant and 5 miles downwind of the affected sub-areas in the Emergency Planning Zone (EPZ); and sheltering all remaining sub-areas in the EPZ. This should include evacuating sub-areas 1,2,3, 12 and sheltering sub areas 4,5,6,7,8,9and 10. This PAR is based on postulated wind direction from the North East (45 degrees) at 8-10 mph.

If chemistry sample was requested following the reactor scram, the reported sample results are 350 uCi/gm 1-131 dose equivalents. (This value meets fission product barrier Loss of Fuel Clad (criteria 3)).

• After an additional. hour (1215 - 1230) and repairs have been made, RWCU valve' M0-1201-02 may be closed to stop the release:

Termination The exercise will be terminated when sufficient time has elapsed to allow appropriate objectives to be demonstrated or evaluated and concurrence from the Commonwealth:

Page 1-4 Updated 9/13/1 ~ 08:00 hrs

Pilgrim Nuclear Power Station 1; November 16th 2016 NRC/FEMA Evaluated Exercise 2 Tjme Line

• Initial Conditions:

• 100% Power

• EOOS Risk XXXX Integrated Risk XXXX Events:

,, Event Elapsed Est Actual Event Details/Expected Actions Expected i

1. Time* Time* Time* Procedures Hr:min

1. -00:30 0730 All Controllers in position at their Emergency I* Response Facility (ERF)

!: 2. -00:30 0730 Initial conditions Established. Simulator operating crew is briefed on the initial conditions. Controllers to provide this

{Message All-001} information to the lead facility players when they arrive.

3. -00:15 0745 Lead Controller Conference line check Conference line check with lead controllers.

Phone: 508-830-7701 pass code 999999

4. -00:05 0755 Control Room Exercise Announcement Control Room (CR) annour:icer makes.

{Message CR-002} announcement over the plant Public Address l(PA) svstem.

5. -00:05 0755 ESB Exercise Announcement Security Personnel or designated controller

{Message SEC-003} makes announcement over the Engineering Support Building Public Address (PA) system.

6. 00:00 0800 Drill/Exercise Commences Controllers and Simulator operating crew players are in position. Scenario begins.

7. 00:02 0802 "A" Travelling Screen Hi D/P intermittent Alarms Operations is monitoring travelling screens at

{Task- 001 Operator} start of exercise.

.,,i Page 2-1 I'

• • All times are *approximate**

Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected

1. Procedures Time* Time* Time*

Hr:min

8. 00:05 0805 Control Rod 26-27 drifts out. Crew will enter ARP-C905LA3 & 2.4.11 & reduce ARP-(This event provides justification for initial > power to -75% (43Mlbs/hr) C905L, indications of fuel damage.) . 2.4.11, Crew calls Rx Engineer to control room. . 2.2.87.2

{Task- 002 Operator}

SM may contact WWM to investigate 26-27

{Message-004 - WWM} drifting.

{Message - 005 - Rx Engineering}

9. 00:20 0820 Operator reports that the sea water bay level has Crew recognizes rising sea level and makes the EP-IP-exceeded 13' 6". This will require declaration of an appropriate classifications HU1 .5. Expect 100 DEP Unusual Event per EAL HU1 .5 Operator dispatched to confirm and monitor Pl water level and travelling screens.

{Task 003 Operator}

UNUSUAL EVENT DECLARED

10. 00:25 0825 UE Announcement CR announcer announces UE over plant PA EP-IP-system. ERO is notified via the E-Plan 100 Att

{Message CR-006} notific~tion system. 9.2 SM may elect to activate any of the Emergency Response Facilities (ERFs) at this time.

Announcement from Simulator will provide info.

11. 00:25 0825 Engineering Support Bldg (ESB) UE Announcement Security Personnel announces UE over plant

{Message SEC-007} . ESB PA svstem.

12. 0835 -0835- Unusual Event EAL HU1 .5 Off-site notification State and local off-site notifications will be 0850 initiated and transmitted.

SIMULATOR CONTROLLER LOG TIME DEP NOTIFICATION TRANSMITTED Pl ...

Page 2-2

• • All times are approximate**

1' Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise i~

I Event Elapsed Est Actual Event Details/Expected Actions Expected

,. Procedures

1. Time* Time* Time*

Hr:min

13. 00:40 0840 If requested, Chemistry to obtain coolant sample. Main Steam and Off-gas radiation levels are 2.4.40

{Task 004} trending upward due to fuel failure occurring from 7.4.64 Att the rod drift. First MSL Rad Alarm on EPIC. 29 All Rad readinQs will be Normal.

14. At least Contingency UE message. Controllers will issue this message only if the UE 20 has not been declared by this time and have minutes {Message SIM-OOSX} approval from Lead Drill Coordinator.

after indication s

15. 0050 -0850 Alert per EAL HA 1.6 Crew recognizes rising sea level and Operator at sea water bay reports back reading. SM should EP-IP-.

DEP Field reports that sea water intake levels are +16'4" 100 declare upgrade to Alert per EAL HA1.6 - Sea Pl 5.3.8 and continuing to rise slowly. (Visual measurement) water bay water level > +16' O" MSL (LI-3831A/B)

{see Task-003 -. Ops}

--- Operator may be sent to screen house with portable device to perform 5.3.8 Attachment 3

16. 0100 0900 Alert Announcement CR announcer announces Alert over plant PA (Message CR-009} system. ERO is notified via the ERO notification system.

17. 0102 0902 Engineering Support Bldg (ESB) Alert Security Personnel announces ALERT over plant Announcement ESB PA system.

(Message SEC-010}

I

18. 0105- -0905- Alert EAL HA1.6 Off-site notification State and local off-site notifications will be 0120 0920 initiated and transmitted for upgrade to Alert.

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• • All times are approximate**

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Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected

1. Time* Procedures Time* Time*

Hr: min

19. At least Contingency Alert message. Controllers will issue this rnessage only if the 20 Alert has not been declared by this time and minutes {Message SIM-011 X} have approval from Lead Drill Coordinator..

after indication s

20. 01:00 0900 Main Steam Line (MSL} "B Flow indicator fails Crew may request l&C Techs to investigate. Fl-downscale due to transmitter failure. 640-238.

{Task 004 - l&C Techs}

21. 0105 0905 Emergency Response Organization (ERO) The ERO should be mobilizing and activating EP-IP-Mobilization Emergency Response Facilities. 100 (unless activated at Unusual Event)

22. 0140 0940 Chemistry reports results from coolant sample if _ Chemistry Technician reports results from taken. sample

{Task 005 - Chem Techs}

Isotope micro curies/cc 1-131 3.65E-0.3 1-132 3.69E-03 1-133 2.35E-03 1-134 O.OOE+OO

.. 1-135 9.30E-04 Dose Equivalent (DE) iodine 4.09E-03

23. 0132 0942 EOG "A" trouble alarms comes in due to low system Operator to investigate.

air pressure.' (Upon investigation will hear air blowing, relief

' {Task-006 - Ops/Mech} valve liftina and not reseatina)

. 24. 0145 0945- TSC/OSC and EOF operational (approximately 60 TSC, OSC and EOF should be made EP-IP-1005 minutes maximum after ERO activation operational. On-call EOF Emergency Director 100 announcement) should take over command and control from the Shift Manager (SM) .

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• • All times are approximate**

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Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected

1. Procedures Time* Time* Time*

Hr:min j* 25. 0150 0950 OSC!TSC assign team to replace relief valve on After Operator reports that relief valve is lifting EDG"A" and notreseating, -osc Team to replace valve.

{Task 007 - Mechanical}

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• • All times are approximate**

Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected Procedures

1. Time* Time* Time*

Hr:min

26. 0215 -1015 A steam leak develops on the RWCU line (-20 Operators enter EOP-04 based on the rising -~

EOP-04 gpm) and will not isolate (Supply valves M01201-02 Secondary Containment Temperatures and and M0-1201-05 will not close). Secondary Radiation levels in the RWCU area, The reactor Containment Temperature and radiation INCREASE is scrammed per EOP-04 when max normal TO Max Normal values. vah.,ies are reached with a primary system Conditions are met for a SAE based on: discharging into secondary containment.

EAL FS1 .1 "Loss of two barriers" Criteria 9 or 14 & 18. Crew will request an operator to go to the RWCU to investigate for steam leak. Operators should RAD readings: Continuous Air Monitors outside of determine that a steam leak has occurred in the RWCU Hx start to alarm at 4 DAC. RWCU HX Room and RWCU fails to isolate.

,.)

The RWCU supply isolations will not close.

Contamination levels from steam coming out is 12K Attempts from the simulator control room are dpm/100 cm2; Rad Levels in outer hallway 50 unsuccessful mrem/hr'.

If personnel get near RWCU Hx Room door then General area around MOV-5 is 1500 mrem/hr with they will_ be contaminated and will not pass the high contamination 150K dpm/100cm2. 6 DAC in exit monitors unless they are wearing proper room. PC's. If contaminated, they will follow decontamination process.

Operator sent out to determine steam leak per EOP-4. Initial attempts to close these valves from their breakers will also be unsuccessful. (480 V MCC

,. {Task-

- 008 Ops } B-20 & 125 voe D-7)

{Task - 009 Electrical}

{Task - 010 Mechanical} The following alarms/indications are received:

RWCU Temp Alarm comes in.

A radioactive steam leak is occurring in the Reactor Building. (Area Temperature, Fire Alarm

.. and Area Radiation Monitor on Rx Bldg Elevation 51' are alarming).

Operators should enter EOP-04 (Secondary

~

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-::::i- -

Containment Control) .

• • All ~imes are approximate**

il Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected

1. Procedures I' Time* Time* Time*

Hr: min

27. 0215 1015- Site Area Emergency (SAE) Declared per The Emergency Director in the EOF is expected EP-IP-1030 EAL FS1.1 ' to upgrade the event to a SITE AREA 100 EMERGENCY (SAE) per EAL FS1 .1 DEP Pl Loss or potential loss of any two barriers: Criteria 9 or 14 and 18 Time starts when crew recognizes they cannot

,, isolate the leak.

28. 0220 1020 Main Steam and Off-gas Rad Monitors alarm. Main Steam and Off-gas radiation levels are , ARP-trending upward due to fuel failure from the rod C904LC drift and SCRAM. PNPS procedure 2.4.40, A6 & 86, "Rapid Increase.in Main Steam Line or Offgas 2.4.40 Activity" directs Main Steam Isolation Valve (MSIV) closure upon reaching High-High set point. Crew may isolate MS IVs *before reaching set point.

29. 0220 1020 Reactor Scram Scram transient causes more fuel damage

30. 0225 1025 Reactor Scram CR announces SCRAM over plant PA system.

{Message CR-012}

31. 0228 1028 Reactor Scram Security Personnel or designated controller

{Message ESB-013} announces SCRAM over plant PA system_.

32. 0230 1030 SAE Announcement CR announcer announces SAE over plant PA system. State and local off-site notifications will

{Message CR-014} be initiated and transmitted of upgrade to SAE.

1:

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• • All times are approximate**

Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected Procedures

1. Time* Time* Time*

Hr:min

33. 0233 1033 Engineering Support Bldg (ESB) SAE Security announces SAE over plant ESB PA Announcement system.

• {Message SEC-015}

34. 0230 10:30 Post Scram actions tp be performed by: Rad conditions: Scram Surveys are taken. 2.1.6 Piping in overtiead of scram header is now 7.4.64

{Task - 011 RP} reading 250 mrem/hr 6.1-220 contamination level: west bank of HCUs 90K dpm/100cm2

{Task - 012 Ops} Operators sent to close CRD 25 valve and remove condensate demineralizers from service.

{Task - 013 Chemistry} Chemistry to obtain sample.

RP's will perform Post Scram surveys per PNPS 6.1-220; "Radiological Controls for High Risk Evolutions"

35. 0230 -1030- SAE EAL FS1 .1 Off-site Notification State and local off-site notifications will be 1045 ** initiated and transmitted of upgrade to Site Area Emergency.

DEP Pl

36. At least 20 Contingency SAE message. Controllers will issue this message only if the minutes SAE has not been declared by this time and after {Message EOF-01 SX}

indications have approval from Lead Drill Coordinator.

37. 0240 1040 JIC activated JIC should be activated - may be sooner but have 2 hr response Page 2-8

• • All times are approximate**

I' Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected

1. Time* Time* Time* Procedures Hr:min

38. 0330 -1130

• Torus High Range Monitor exceeds 50R/hr Staff should recognize the Torus High Range EP-IP-Monitor exceeds 50R/hr as an indication of failed 100 Att Conditions are met for a GE based on:

fuel clad barrier and combined with the SAE 9.5 EAL FG1 .1 "Loss of two barriers and loss or conditions, this meets GE criteria. EP-IP-potential loss of third barrier". Criteria: 2, 9 or 14 400 Radiation level: 20-50 mrem/hr General area in and 18.

23' RB Crew requests starting all available turbine roof exhaust fans.(Control Room High Efficiency Air Filtration System - CRHEAFS)

The Emergency Director in the EOF is expected

'to* upgrade to a GENERAL EMERGENCY (GE) per EAL FG1.1 Loss of two barriers and loss or potential loss of third barrier Criteria: 2, 9 or 14 and 18.

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Pilgrim Nu.clear Power Station November 16111 2016 NRC/FEMA Evaluated Exer.cise Event Elapsed Est Actual Event Details/Expected Actions Expected

1. Procedures Time** Time* Time*

Hr: min

39. 0330 -1130 General Emergency (GE) Declared* Upon confirmation of the status of the Fuel Clad EP-IP-EAL FG1.1 Barrier, RCS Barrier and Primary Containment 100 Att DEP Barrier, the EOF Emergency Director should 9.5 Pl peclare a General Emergency per EAL FG1 .1. EP-IP-Loss of any two Fission Product Barriers and Loss or Potential Loss of the Third Barrier (Table F-1 ) .. 400 This should include declaring the loss of the EOF CONTROLLER LOG TIME GE DECLARED Fission Product Barriers based on the following

• and PAR determination time. EAL conditions contained in EP-IP-100.1 Table F-1.

• Fuel Clad Barrjer Loss of Fuel Clad 2- Torus High Range Rad Monitor >50R/hr RCS Barrjer Loss of the RCS Barrier 9 - Release pathway exists outside Primary Containment resulting from is<;>lation failure in any of the following (excluding normal process system flow paths from an unisolable system):

- Main steam line

- HPCI steam line

- RCIC steam line

-RWCU

- Feedwate.r QB Page 2-10

• • All times are approximate**

. I Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected

1. Procedures Time* Time* Time*

Hr: min (Potential Loss) 14- Unisolable primary system discharge outside primary containment AND A valid entry condition into EOP-04 exists due to

• Secondary Containment area radiation or temperature above any* Maximum Normal Operating Value. (EOP-04 Table H)

Atll2 Prjmarv Contajnment tPCl Barrjer:

Loss of PC 18 - Failure*of any valve in any one line to close AND Direct downstream pathway to the

• environment exists after PC isolation signal.

At the time of declaring the General Emergency, the EOF Emergen~y Director will formulate and .

issue Protective Action Recommendations (PARs) with the initial Genl:lral Emergency declaration to the State EOF representatives.

!' 40. 0336 1130 GE Announcement CR announces GE over plant PA system.

{Message CR-017} -

41. 0338 1132 Engineering Support Bldg (ESB) GE Announcement Security announce~ GE over plant ESB PA i:

I system.

!" {Message SEC-018}

42. 0340 -1145 GE EAL FG1.1 NOTIFICATION State and local off-site notifications will be initiated and transmitted of upgrade to GE.

DEP Pl

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Pilgrim Nuclear Power Station November 16th 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected

1. Time* Time* Time* Procedures Hr: min

43. 0340 -1130- PAR Offsite Notification The PAR should include evacuating the 2 mile 1145 ring surrounding the plant and 5 miles downwind of the affected .sub-areas in the Emergency DEP Planning Zone (EPZ); and sheltering all Pl remaining sub-areas in the EPZ. This should include evacuating sub~areas 1,2,3 and 12 and; sheltering sub areas 4,5,6,7,8,9 and 10, This PAR is based on postulated wind directio~ from the East (45 degrees) at 8-10 MPH.

44. At least 20 Contingency GE message. Controllers will issue this message only if a GE

.minutes has not been declared by this time and have after {Message EOF-019X}

• indications approval from Lead Drill Coordinator.

45. '0420 -1220 If taken and when completed (simulated), If sample is taken post scram, Chemistry reports coolant sample results of 350 RP tech is to take a dose rate of sample 600 uCi/gm 1-131 dose equivalent.

mr/hr on the sample Isotope micro curies/cc 1-131 2.51E+02 1-132 3.54E+02

' 1-133 5.02E+02 1-134 5.61E+02 1-135 4.43E+02 DE iodine 350 This meets Criteria 3 loss of fuel clad.

46. 0415 -1215- OSC team is successful in closing M0-1201-02. OSC team is successful in isolating the leak.

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Pilgrim Nuclear Power Station

., November 16111 2016 NRC/FEMA Evaluated Exercise Event Elapsed Est Actual Event Details/Expected Actions Expected

1. Time* Time* Time* Procedures Hr:min 49 0500 -1300 Exercise Termination ll'tbmannounced by Lead The exercise will be terminated when sufficient Drill Coordinator. time has elapsed to allow appropriate objectives to be demonstrated or evaluated on site and off

{Message CR-020, SEC-021, EOF-022 and All-023} site.

Validate Commonwealth has met extent of play criteria for their portion of the exercise requiring Pilgrim support (and FEMA evaluators concur).

Exercise termination will not be announced until objective demonstration has been confirmed_ as needed per the Lead Drill Coordinator.

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